Is there a viable pathway for PCR sourced and incorporated into finished goods manufactured overseas to qualify as source reduction, assuming the material can be APR certified?
From what I’ve research, the manufacturer of the plastic has to get the APR certificate for the year your product was manufactured. So it matters more on if you can get the certification rather than where it comes from.
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Thank you Kathryn, that is helpful.
APR just launched their own certification standard within the last year because PCR certifiers don’t have a reciprocity agreement and don’t recognize their competitor’s certifications. This means for a plastics manufacturer all of their suppliers must be certified from the same certifier as whoever they wanted to get certified by. And APR only recognize 8 auditing or certifying consultants to certify against their new standard. This is a challenge because many international certifiers like Bureau Veritas who do a lot of business in China are not included. Those 8 approved APR certifiers are listed on their website here: APR PCR Certification - Association of Plastic Recyclers (APR)
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That is very helpful. I’ve heard rumblings of additional certifiers being added.
But for now, my takeaway is, not a lot of opportunity to report certified PCR in California in the current reporting cycle – is that how you would read it?
As I understand it SB-54 does not mandate a minimum PCR content in single use plastics directly, RPPC has been in California requiring PCR in plastic containers since the early 1990s, and another act called AB- 793 passed in 2020 added that requirement to plastic beverage bottles. For SB-54 reporting PCR content has two potential benefits, it is supposed to be an eco-modulator at some point lowering EPR fees for a producer with higher PCR content and it will also count towards source reduction targets, but only for a portion of the required total, the rest needs to come from weight reduction and reuse/refill options.
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