PLASTICS Testifies on California Thermoformed Container Legislation

California State Assembly

Natural Resources Committee

Remarks as prepared for delivery:

Madame Chair and Members of the Committee:

For the record, my name is Shannon Crawford, and I am here as a representative of the Plastics Industry Association. On behalf of PLASTICS and the 61,800 Californians who work in our industry, I am testifying to express our concerns with AB 478, as currently drafted.

Our members strongly support the use of recycled content. We are firmly committed to manufacturing products that meet the environmental, social, and business needs of consumers. The inclusion of Post-Consumer Recycled Plastic, commonly referred to as PCR, in a variety of products can have positive environmental benefits and legislating minimum requirements may be beneficial if done appropriately. Our members have voluntarily begun incorporating recycled content into their packaging.

While this bill would develop end markets for plastic materials, there should be an equal emphasis on improving the collection and sortation of these materials to get more plastics to these markets. Unfortunately, our analysis indicates there will not be sufficient recycled content to meet the mandates of this legislation. We hope to work with this committee and other stakeholders to increase the availability of recycled content in the state to meet the goals of this bill.

One significant barrier that exists to the use of recycled content in food contact materials is food safety regulations. Just last week, our association released industry guidance to ensure recycled plastic packaging meets and exceeds compliance requirements to several U.S. Food and Drug Administration regulations. The guidance document was developed over an extensive two-year process.

Additionally, we are developing a “best practices” workbook for recycled content usage in manufacturing. The workbook will educate the industry on the benefits of recycled content usage as well as assist companies in reaching their sustainability goals.

Despite these advances, there still exists a significant gap between how much recycled content exists and the requirements of this bill. We suggest that to achieve these goals this committee focus on advanced sortation and collection technologies. The Pacific Northwest Demonstration Project was an industry collaboration that showed secondary sorting could significantly increase the amount of recyclable material captured. The further sortation of these materials increases their market value.

We would be happy to work with this committee and other stakeholders to advance solutions that would increase the availability of recycled content in the State. Thank you for your time and I look forward to any questions you may have.

Shannon Crawford

Director, State Government Affairs

Plastics Industry Association