California recycling claims restrictions
On April 4, 2025, the California Department of Resources Recycling and Recovery (CalRecycle) published its Final Findings of the SB 343 Material Characterization Study. The report assesses the recyclability of materials that are collected in California's curbside recycling programs and sorted by large volume transfer/processing facilities (LVTP facilities).
SB 343 mandated that the report provide critical data on the types and forms of materials accepted for recycling and on the sorting facilities serving a significant portion of the state’s population. CalRecycle’s report responds to that mandate by setting forth comprehensive, data-driven identification of which materials are actually collected, sorted, and recycled in California’s curbside programs, offering a clear baseline for companies to design products and packaging that meet the state’s recyclability and material reduction requirements under SB 54. It also establishes specific criteria for recyclability labeling under SB 343, clarifying which materials and forms qualify for the chasing arrows symbol and supporting producers in complying with Extended Producer Responsibility (EPR) obligations by aligning product labeling and design with real-world recycling practices.
SB 343 and SB 54: How they relate
SB 343, enacted in 2021, prohibits the use of the chasing arrows symbol or any other indicator of recyclability on products and packaging unless producers can demonstrate that certain criteria are met. It also places responsibility for recyclability labeling on the producer of the product and packaging. Manufacturers and other interested parties will have to use the report as part of their assessment of whether products may be considered recyclable for labeling purposes.
SB 54, enacted in 2022, aims to reduce plastic pollution and increase recycling rates by requiring producers to fund the disposal of their products and increase the circularity of those products. SB 54 requires producers of single-use packaging and plastic food service ware to meet recycling targets and reduce the use of non-circular materials.
Key findings and implications
The report provides a baseline understanding of the common materials collected, sorted, sold, or transferred for recycling in California. It translates the different materials identified in CalRecycle’s surveys into SB 343 material type and form results (Appendix 1, Section 1.1). It also categorizes the various material types and forms that can be properly classified as “Sorted for Recycling” (Appendix 1, Section 2.7, Table J1).
By referencing this list, producers can select materials for packaging and products that are recognized as recyclable, supporting compliance with SB 54’s design-for-recyclability requirements. The report also notes that future studies will be designed to better align with covered materials categories for SB 54 to further assist producers in meeting their obligations.
Differences from earlier iterations
The report incorporates several revisions and updates from earlier iterations published by CalRecycle:
- Updated data and methodology: The report includes updated numbers of counties served by the various Materials Recovery Facilities (MRFs), transfer stations, reprocessors, composting operations, and specialty processor facilities surveyed, encompassing 93 percent of California's population. This update reflects the inclusion of additional counties served by two study facilities, verified by CalRecycle’s collected survey data.
- Clarification of material types and forms: The report clarifies the material types and forms list to more accurately represent the materials accepted and sorted by recycling programs and facilities.
- Additional data collection: The report incorporates additional material characterization sampling conducted in January and February 2024, providing a more comprehensive understanding of the materials sorted by LVTP facilities.
Key takeaways to ensure SB 54 compliance
- Understanding commonly recycled materials: The report provides detailed data on the types and forms of materials that are commonly collected, sorted, sold, or transferred for recycling in California. This information is key to designing products and packaging that meet SB 54’s recyclability criteria.
- Enhancing recyclability labeling compliance: The report outlines the criteria for recyclability labeling under SB 343, which includes being accepted for collection by municipal recycling programs and being sorted into defined streams by LVTP facilities. These criteria allow companies to determine whether their products qualify to use the chasing arrows symbol, or other recyclability indicators.
- Adjusting EPR programs: The report highlights the importance of collaboration with recycling facilities, and the need for effective material sorting processes. Companies may be required to modify product packaging, improve material sorting processes, and work closely with LVTP facilities to ensure that their products are sorted into the appropriate recycling streams.
- Meeting recycling rates and material reduction targets: The report provides data to help companies understand which materials are commonly recycled, and which are not. For each major material category (eg, polyethylene terephthalate (PET) bottles, high-density polyethylene (HDPE) containers, glass, aluminum, paper grades, certain plastics, among others), the report identifies: (1) the percentage of California’s population served by programs that collect the material (Appendix 1, Section 2.1, Table D1), (2) the extent to which the material is sorted at MRFs (Appendix 1, Section 2.3, Table F1), and (3) the proportion of the material that is actually sent to reprocessors and successfully recycled (Appendix 1, Section 2.7, Table J1). This information may help companies set targets and develop strategies to meet SB 54’s recycling rate and material reduction goals.
Conclusion
The final findings of the report provide key data for companies to comply with California's recyclability labeling requirements and EPR obligations under SB 343 and SB 54. Understanding the materials commonly recycled in California will allow companies to make informed decisions about product design, material selection, and EPR program adjustments to meet the state's recycling and circularity goals.
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