The regulation impacts any manufacturer selling products in RPPCs in California. Adhesive and sealant manufacturers have been complying with this law since 1991, but the California Integrated Waste Management Board (CIWMB) recently eliminated certain exemptions which may draw additional products into required compliance.
Change highlights include:
Number of Closures – original law regulated only containers “capable of multiple closures” with attached or unattached lid but new revision eliminates distinction between single and multiple use containers. For example, previously only sealant cartridges with “lid tip” were regulated now all sealant cartridges must meet regulation requirements.
Background: The regulation requires that manufacturers selling materials into California utilizing RPPCs must be able to demonstrate one of the following options for their containers
Upon a CIWMB audit, companies would establish compliance by providing information from their RPPC supplier that their packaging meets one of the requirements for recycled material.
The rule revision became effective January 1, 2013.
Next Steps: Companies whose packaging may be affected by this rule for the first time should contact their RPPC supplier immediately to develop a strategy for integrating compliant packaging into their product line.
Director of Regulatory Affairs