California Clarifies Nov. 15 EPR Reporting Deadline Not Mandatory

A week after FEDA and other business advocacy groups urged California to delay a reporting deadline under its new EPR law, the state has clarified that the reporting is not mandatory.

The Circular Action Alliance (CAA), the privately run producer responsibility organization chosen to facilitate California’s extended producer responsibility (EPR) program, had set an initial reporting date of Nov. 15 for companies covered by the state’s EPR law, which includes many distributors that sell packaged products in the state. However, CalRecycle, the state’s recycling agency, has now explained that this reporting date is voluntary and was requested by CAA to support the development of its Producer Responsibility Plan and source reduction baseline reporting.

FEDA, the National Association of Wholesaler-Distributors (NAW) and other business groups raised concerns about the Nov. 15 deadline because it overlapped with the 45-day public comment period for proposed regulations for the implementation of the EPR law. Had reporting been mandatory, it would have forced distributors and other businesses to submit information about the amount of packaging materials they sell or produce before those regulations were finalized.