SB 54 Report to the Legislature
December 2023Recyclability Status
of Covered Material
Categories 
Staff Report    i 
 State of California  
Gavin Newsom  
Governor  
 
California Environmental Protection Agency  
Yana Garcia  
Secretary  
Department of Resources Recycling and Recovery (CalRecycle)  
Rachel Machi Wagoner  
Director  
Public Affairs Office  
1001 I  Street  (MS 22-B) 
P.O. Box 4025  
Sacramento, CA  95812 -4025  
www.calrecycle.ca.gov/Publications/  
1-800-RECYCLE  (California only) or (916) 341 -6300  
Publication #  DRRR -2023 -1729  
To conserve resources and reduce waste, CalRecycle reports are pro duced  in 
electronic format only. If printing copies of this document, please consider use 
of recycled paper containing 100 percent postconsumer fiber and,  
where possible, please print  on both sides.  
Copyright ©  2023  by the California Department of Resources Recycling and 
Recovery  (CalRecycle) . All rights reserved. This publication, or parts thereof, 
may not be reproduced in any form without permission.  This report was 
prepared by staff of CalRecycle  to provide information or technical assistance.  
The statements and conclusions of this report are those of CalRecycle  staff and 
not necessarily those of the department  or the State of California. The state 
makes no warranty, expressed or implied, and assumes no liability for the 
information contained in the succeeding text. Any mention of commercial 
products or processes shall not be construed as an endorsement of such 
products or processes.  
CalRecycle  does not discriminate on the basis of disability in access to its 
programs. CalRecycle publications are available in accessible formats upon 
request by calling the Public Affairs Office at (916) 341 -6300. Persons with 
hearing impairments can reach CalRecycle  through the California Relay Service  
at 1-800-735-2929.   
Staff Report    i 
 Table of Contents  
Table of Contents  ................................ ................................ ................................ .............  i 
Executive Summary  ................................ ................................ ................................ ........  1 
Introduction  ................................ ................................ ................................ .....................  2 
SB 54 Background  ................................ ................................ ................................ ..... 2 
SB 54 Recyclability Background  ................................ ................................ ................  3 
SB 343 Background  ................................ ................................ ................................ ... 3 
Summary of Findings  ................................ ................................ ................................ ...... 5 
Materials Accepted by Recycling Programs  ................................ ...............................  5 
Materials Recovered by Large Volume Transfer/Processors  ................................ ..... 5 
Considering Population Served by LVTPs  ................................ ................................ . 5 
Summary Tables  ................................ ................................ ................................ ........  6 
Methods, Assumptions, and Limitations  ................................ ................................ ........  18 
Methods  ................................ ................................ ................................ ...................  18 
Assumptions  ................................ ................................ ................................ ............  21 
Limitations  ................................ ................................ ................................ ................  22 
Abbreviations and Acronyms  ................................ ................................ .........................  23 
   
Staff Report      1 
 
Executive Summary  
The Plastic Pollution Prevention and Packaging Producer Responsibility Act  (SB 54, 
Allen, Chapter 75, Statutes of 2022 ) requires that all covered material sold in California, 
which consists of single -use packaging and single -use plastic food ware, be recyclable 
and/or compostable by 2032.  
SB 54 requires CalRecycle to use criteria established by SB 343 ( Allen, Chapter 507, 
Statutes of 2021 ) to evaluate the recyclability of covered material categories ( CMCs ). 
For materials to considered  recyclable, in addition to meeting product -specific criteria  
established by SB 343 , they must be:  A type and form of material accepted by 
jurisdiction recycling programs providing service to at least 60% of the population of the 
state ; and be recovered and sorted into defined streams by large volume transfer 
processors (LVTPs) providing service to at least 60% of statewide recycling programs.  
CalRecycle collected information provided by local jurisdictions on the accepted 
materials from their recycling programs, conducted surveys, and conducted site 
characterization work at LVTPs throughout California.  LVTPs receive deliveries from 
curbside haulers, sort material into individual types, bale it, and then process it into 
feedstock (like plastic pellets made from plastic water bottles) for manufacturers to use 
in new products.  CalRecycle collected data to provide representative information on 
how m aterial collected through curbside pickup is processed for recycling by LVTPs in 
California. CalRecycle used th e available  data to evaluate the recyclability status of 
CMCs.  
 
CalRecycle determined that 37 out of 9 8 CMCs meet both criteria evaluated as part of 
this analysis. These CMCs generally consist of materials that have established and 
robust recyclable material market s, meaning that processors have a buyer for the 
recycled -content feedstock they produce.  
This data is presented by CMC in the results section of this report . A list of CMCs that are 
potentially recyclable per the two criteria established by SB 343 is provided in Table 1.  
The information provided in this report is not a determination of recycling label ing 
eligibility or legality pursuant to SB 343 . CalRecycle does not have authority under SB 
343 to make such determinations.   38% of Covered Material Categories Are 
Recyclable in California , including most types of:  
• Glass  
• Aluminum  
• Cardboard  
• Paper  
• Plastics 1, 2, and 5   
Staff Report      2 
 
Introduction  
SB 54 established The Plastic Pollution Prevention and Packaging Producer 
Responsibility Act .  SB 54 requires CalRecycle to report to the Legislature on whether  
single -use packaging and single -use plastic food ware sold in California meet the 
definition of recyclability as outlined in SB 343.  This report satisfies that requirement.  
This report will highlight:  
• SB 54 requirements related to publishing information about CMC recyclability 
[see Public Resources Codes (PRC) Section 42061(1)(3)(B) and 42061(c)];  
• SB 343 and Title 14, Section 17989.2 of the California Code of Regulations; and  
• How CalRecycle has evaluated material category recyclability based on 
information collected pursuant to PRC Section 42355.51(d)(1).  
This report provides the necessary available  information to the Legislature about how 
many products currently sold into California’s economy are recyclable within the state’s 
current recycling infrastructure. The related list of CMCs that meet the criteria of 
recyclability will provide the necessary  available  information to manufacturers and the 
public about what types of single -use packaging  and single -use plastic  food service 
ware  are considered recyclable for purposes of SB 54 .  
SB 54 Background  
Packaging waste makes up 27% of what we dump in California landfills.  
We must reduce packaging waste and ensure it gets recycled to meet our state’s 
recycling and climate goals.  
SB 54 requires that by 2032 we:  
• Cut by 25% single -use plastic packaging and food service ware , 
• Recycle 65% of single -use plastic packaging and food service ware , and  
• Make 100% of single -use packaging and plastic food service ware recyclable or 
compostable . 
SB 54 establishes a new extended producer responsibility (EPR) program to manage 
covered material, which encompasses single -use packaging and single -use plastic food 
service ware products across every sector of the economy. Producers will ensure that  
Staff Report      3 
 
the covered material  sold, offered for sale , distributed, or imported  in or into California is 
recyclable or compostable.  
EPR gives primary responsibility for managing products after their useful life to 
producers, who can design and market products to be more easily reused or recycled. 
EPR can encourage product design changes to:  
• Ensure products are easily reused or recycled , and  
• Minimize negative impacts on public health and the environment at every stage 
of the product’s lifecycle . 
SB 54 Recyclability Background  
Public Resources Code (PRC) section 42061 (a)(3)B) requires that  “The department 
shall, on or before January 1, 2024, report to the Legislature in compliance with Section 
9795 of the Government Code on the status of material types relative to the 
requirements in subparagraphs (A) and (B) of paragraph (2) of subdivision ( d) of 
Section 42355.51. ” 
Additionally, SB 54 establishe s a requirement in PRC Section 42061 (c) that “By January 
1, 2024, the department shall publish on its internet website a list of covered material 
categories that are, based on available collection and processing infrastructure and 
recycling markets, deemed recyclable as of January 1, 2024. Covered materi al is 
deemed recyclable if it meets the requirements of Section 17989.2 of Title 14 of the 
California Code of Regulations, as that section existed on January 1, 2023, and Section 
42355.51. ” 
While this report focuses on meeting the requirement established by PRC 
42061( a)(3)(B) , information summarized in this report is also related to and will coincide 
with the list published by CalRecycle pursuant to PRC section 420 61(c). 
SB 343 Background  
Many Californians rely on the chasing arrows symbol to tell if an item  is recyclable.  Until 
the passage of SB 343 , California did not set specific standards for when the recycling 
logo could be used on products.  SB 343 prohibit s the use of the chasing arrows symbol 
or any other indicator of recyclability on products and packaging unless they are 
collected, sorted, and recovered for recycling in California.  
SB 343 requires CalRecycle to publish data about the material types and forms that are 
collected, sorted, and processed for recycling  in California. Manufacturers and the 
public can use this information to evaluate whether a product or packaging can be 
labeled  recyclable in the state.   
Staff Report      4 
 
SB 343 directs CalRecycle to conduct and publish a material characterization study 
(MCS) of material types and forms  that are collected, sorted, sold, or transferred by 
solid waste facilities  [see PRC Section 42355.51(d)(1)(B)] . 
A product or packaging may be considered recyclable for purposes of labeling and 
recyclability claims if, based on information published by CalRecycle, the product or 
packaging is of a material type and form that is both:  
1. Collected for recycling by recycling programs for jurisdictions that collectively 
encompass at least 60 percent of the population of the state  [see 
42355.51(d)(2)(A)] ; and  
2. Sorted into defined streams for recycling processes by large volume 
transfer/processing facilities, that collectively serve at least 60 percent of 
recycling programs statewide  [see 42355.51(d)(2)(B)(i)] .  
SB 343 also established additional criteria for specific products and materials to be 
eligible to be labeled as recyclable [see PRC Section 42355.51(d)(3)].  Additionally, 
SB 343 established alternative criteria for materials that do not qualify as recyclable 
through the traditional curbside collection and solid waste handling infrastructure 
criteria.  While CalRecycle will be evaluating covered material categories (single -use 
packaging and plastic food service ware) for purposes of SB 54, that evaluation w ill not 
consider PRC sections 42355.51(d)(3) through (d)(6), which apply only to specific 
products, not categories of materials.  
   
Staff Report      5 
 
Summary of Findings  
A list of CMCs that are potentially recyclable per the criteria established by SB 343 is 
provided in Table 1.  The status of CMCs relative to the criteria established by 
42355.51(d)(2)  is summarized in  Table 2 .  
Out of 98 CMCs , 37, or 37% , meet both criteria established by 42355.51(d)(2) . 
Materials Accepted by Recycling Programs  
Out of 98 CMCs , 48, or 49%, are accepted for collection by jurisdiction recycling 
programs collectively  servic ing to at least  60 percent of California’s population.  
Materials Recovered by Large Volume 
Transfer/Processors  
Out of 98 CMCs , 42, or 43%, are recovered by LVTPs that collectively service at least 
60 percent of recycling programs in California.  
Considering Population Served by LVTPs  
CalRecycle has provided available information that identifies the percentage  of 
California’s population that is served by LVTPs that recover a specific CMC. 58 of 9 8 
CMCs, or 59%, are sorted and processed by LVTPs serving 60% or more of the state’s 
population. This information is interesting because it highlights the potential difference 
between recycling programs served and population served, in that often more popul ous 
regions are serviced by LVTPs that recover a wider range of materials than lower 
popula tion areas.  
As a result, for some material types, the number of counties  that have LVTPs available 
to them may not meet the 60% threshold, while the percent of the population  with an 
LVTP serving them does meet the 60% threshold.    
Staff Report      6 
 
Summary Tables  
Table 1. Covered Material Categories (CMCs) that are potentially recyclable per 
PRC Section 42355.51(d)(2)  
Covered Material Category Name  
Glass - Bottles and Jars w/o plastic component  
Glass - Bottle and Jars w/ plastic component  
Glass - Small - No side greater than 2” w/o plastic component  
Glass - Small - No side greater than 2” w/ plastic component  
Aluminum - Non-aerosol container w/o plastic component  
Aluminum - Non-aerosol container w/ plastic component  
Aluminum - Foil sheets w/o a plastic component  
Aluminum - Foil sheets w/ a plastic component  
Aluminum - Foil Molded Containers w/o plastic component  
Aluminum - Foil Molded Containers w/ plastic component  
Aluminum - Aerosol can w/ plastic component  
Metal - Small - No side greater than 2” w/o plastic component  
Metal - Small - No side greater than 2” w/ plastic component  
Kraft Paper - All Forms w/o plastic component  
Kraft Paper - All Forms w/ plastic component  
Molded Fiber - All Forms of Packaging w/o plastic component  
OCC - Cardboard w/o plastic component  
OCC - Cardboard w/ plastic component  
Paperboard - All Forms w/o plastic component  
Paperboard - All Forms w/ plastic component  
White Paper - All Forms w/o plastic component  
White Paper - All Forms w/ plastic component  
Other/Mixed Paper - All Forms w/o plastic component  
Other/Mixed Paper - All Forms w/ plastic component  
Paper/Fiber - Small - No side greater than 2” w/o plastic component  
Paper/Fiber - Small - No side greater than 2” w/ plastic component  
PET (#1) - Bottles, Jugs, and Jars (Clear/Natural)  
PET (#1) - Bottles, Jugs, and Jars (Pigmented/Color)  
PET (#1) - Thermoformed Containers, Cups, Lids, Plates, Trays  
PET (#1) - Other Rigid Items (including containers)  
HDPE (#2) - Bottles, Jugs and Jars (Clear/Natural)  
HDPE (#2) - Bottles, Jugs and Jars (Pigmented/Color)  
HDPE (#2) - Pails & Buckets  
HDPE (#2) - Other Rigid Items (including containers)  
PP (#5) - Bottles, Jugs and Jars  
PP (#5) - Thermoformed Containers, Cups, Lids, Plates, Trays, Tubs  
PP (#5) - Other Rigid Items   
Staff Report      7 
 
Table 2. Collection and Recovery of CMC s According to Jurisdiction Survey and 
Facility Study  
Category 
ID Covered Material 
Category (CMC)  Percentage of 
Population with 
Collection of 
CMC for 
Recycling  Percentage of 
Surveyed 
Counties 
Served by 
MRFs 
Recovering 
CMC  Percentage of 
Surveyed 
Population 
Served by 
MRFs 
Recovering 
CMC  
GC1N  Glass - Bottles and 
Jars w/o plastic 
component   95% 100%  100%  
GC1P  Glass - Bottle and 
Jars w/ plastic 
component   95% 100%  100%  
GC2N  Glass - Other 
Forms w/o plastic 
component   11% 100%  100%  
GC2P  Glass - Other 
Forms w/ plastic 
component   11% 100%  100%  
GC3N  Glass - Small - No 
side greater than 
2” w/o plastic 
component   95% 100%  100%  
GC3P  Glass - Small - No 
side greater than 
2” w/ plastic 
component   95% 100%  100%  
GC4N  Ceramic - All 
Forms w/o plastic 
component   0.8%  No Data  No Data  
GC4P  Ceramic - All 
Forms w/ plastic 
component   0.8%  No Data  No Data  
GC5N  Ceramic - Small - 
No side greater 
than 2” w/o plastic 
component   0.8%  No Data  No Data   
Staff Report      8 
 
Category 
ID Covered Material 
Category (CMC)  Percentage of 
Population with 
Collection of 
CMC for 
Recycling  Percentage of 
Surveyed 
Counties 
Served by 
MRFs 
Recovering 
CMC  Percentage of 
Surveyed 
Population 
Served by 
MRFs 
Recovering 
CMC  
GC5P  Ceramic - Small - 
No side greater 
than 2” w/ plastic 
component   0.8%  No Data  No Data  
M1N  Aluminum - Non-
aerosol container 
w/o plastic 
component   95% 73% 91% 
M1P Aluminum - Non-
aerosol container 
w/ plastic 
component   95% 73% 91% 
M2N  Aluminum - Foil 
sheets w/o a 
plastic component   70% 73% 91% 
M2P Aluminum - Foil 
sheets w/ a plastic 
component   70% 73% 91% 
M3N  Aluminum - Foil 
Molded Containers 
w/o plastic 
component   70% 73% 91% 
M3P Aluminum - Foil 
Molded Containers 
w/ plastic 
component   70% 73% 91% 
M4P Aluminum - 
Aerosol can w/ 
plastic component   92% 73% 91% 
M5N  Aluminum - Other 
Forms w/o plastic 
component   24% 73% 91%  
Staff Report      9 
 
Category 
ID Covered Material 
Category (CMC)  Percentage of 
Population with 
Collection of 
CMC for 
Recycling  Percentage of 
Surveyed 
Counties 
Served by 
MRFs 
Recovering 
CMC  Percentage of 
Surveyed 
Population 
Served by 
MRFs 
Recovering 
CMC  
M5P Aluminum - Other 
Forms w/ plastic 
component   24% 73% 91% 
M6N  Tin/Steel/Bimetal - 
Non-aerosol 
container w/o 
plastic component   95% 33% 65% 
M6P Tin/Steel/Bimetal - 
Non-aerosol 
container w/ 
plastic component   95% 33% 65% 
M7P Tin/Steel/Bimetal - 
Aerosol can w/ 
plastic component   91% 33% 65% 
M8N  Tin/Steel/Bimetal - 
Other Forms w/o 
plastic component   24% 33% 65% 
M8P Tin/Steel/Bimetal - 
Other Forms w/ 
plastic component   24% 33% 65% 
M9N  Other Nonferrous - 
All Forms w/o 
plastic component   20% 47% 83% 
M9P Other Nonferrous - 
All Forms w/ 
plastic component   20% 47% 83% 
M10N  Other Ferrous - All 
Forms w/o plastic 
component   20% 33% 65% 
M10P  Other Ferrous - All 
Forms w/ plastic 
component   20% 33% 65%  
Staff Report      10 
 
Category 
ID Covered Material 
Category (CMC)  Percentage of 
Population with 
Collection of 
CMC for 
Recycling  Percentage of 
Surveyed 
Counties 
Served by 
MRFs 
Recovering 
CMC  Percentage of 
Surveyed 
Population 
Served by 
MRFs 
Recovering 
CMC  
M11N  Metal - Small - No 
side greater than 
2” w/o plastic 
component   96% 60% 87% 
M11P  Metal - Small - No 
side greater than 
2” w/ plastic 
component   96% 60% 87% 
PF1N  Kraft Paper - All 
Forms w/o plastic 
component   93% 90% 93% 
PF1P  Kraft Paper - All 
Forms w/ plastic 
component   85% 90% 93% 
PF2P  Molded Fiber - All 
Forms of Food 
Service Ware w/ 
plastic component   38% No Evidence of 
Sorting  No Evidence of 
Sorting  
PF3N  Molded Fiber - All 
Forms of 
Packaging w/o 
plastic component   62% 100%  100%  
PF3P  Molded Fiber - All 
Forms of 
Packaging w/ 
plastic component   58% No Evidence of 
Sorting  No Evidence of 
Sorting  
PF4P  Multi -Material 
Laminate - Aseptic 
Containers   46% 27% 55% 
PF5P  Multi -Material 
Laminate - Gable -
top Cartons   49% 27% 55%  
Staff Report      11 
 
Category 
ID Covered Material 
Category (CMC)  Percentage of 
Population with 
Collection of 
CMC for 
Recycling  Percentage of 
Surveyed 
Counties 
Served by 
MRFs 
Recovering 
CMC  Percentage of 
Surveyed 
Population 
Served by 
MRFs 
Recovering 
CMC  
PF6P  Multi -Material 
Laminate - Poly-
coated food 
service ware   38% No Evidence of 
Sorting  No Evidence of 
Sorting  
PF7P  Multi -Material 
Laminate - Other 
Forms w/ plastic 
component   0% No Evidence of 
Sorting  No Evidence of 
Sorting  
PF8N  OCC - Waxed 
Cardboard w/o 
plastic component   0% No Evidence of 
Sorting  No Evidence of 
Sorting  
PF8P  OCC - Waxed 
Cardboard w/ 
plastic component   0% No Evidence of 
Sorting  No Evidence of 
Sorting  
PF9N  OCC - Cardboard 
w/o plastic 
component   94% 100%  100%  
PF9P  OCC - Cardboard 
w/ plastic 
component   84% 100%  100%  
PF10N  Paperboard - All 
Forms w/o plastic 
component   86% 90% 93% 
PF10P  Paperboard - All 
Forms w/ plastic 
component   75% 90% 93% 
PF11N  White Paper - All 
Forms w/o plastic 
component   90% 100%  100%  
PF11P  White Paper - All 
Forms w/ plastic 
component   80% 100%  100%   
Staff Report      12 
 
Category 
ID Covered Material 
Category (CMC)  Percentage of 
Population with 
Collection of 
CMC for 
Recycling  Percentage of 
Surveyed 
Counties 
Served by 
MRFs 
Recovering 
CMC  Percentage of 
Surveyed 
Population 
Served by 
MRFs 
Recovering 
CMC  
PF12N  Other/Mixed Paper 
- All Forms w/o 
plastic component   95% 90% 93% 
PF12P  Other/Mixed Paper 
- All Forms w/ 
plastic component   84% 90% 93% 
PF13N  Paper/Fiber - 
Small - No side 
greater than 2” w/o 
plastic component   97% 90% 93% 
PF13P  Paper/Fiber - 
Small - No side 
greater than 2” w/ 
plastic component   97% 90% 93% 
P1P PET (#1) - Bottles, 
Jugs, and Jars 
(Clear/Natural)   94% 100%  100%  
P2P PET (#1) - Bottles, 
Jugs, and Jars 
(Pigmented/Color)   94% 100%  100%  
P3P PET (#1) - 
Thermoformed 
Containers, Cups, 
Lids, Plates, 
Trays , Tubs   82% 100%  100%  
P4P PET (#1) - Other 
Rigid Items 
(including 
containers)   89% 100%  100%  
P5P PET (#1) - Flexible 
and Film Items   30% 37% 60% 
P6P HDPE (#2) - 
Bottles, Jugs , and  94% 100%  100%   
Staff Report      13 
 
Category 
ID Covered Material 
Category (CMC)  Percentage of 
Population with 
Collection of 
CMC for 
Recycling  Percentage of 
Surveyed 
Counties 
Served by 
MRFs 
Recovering 
CMC  Percentage of 
Surveyed 
Population 
Served by 
MRFs 
Recovering 
CMC  
Jars 
(Clear/Natural)  
P7P HDPE (#2) - 
Bottles, Jugs , and 
Jars 
(Pigmented/Color)   94% 100%  100%  
P8P HDPE (#2) - Pails 
& Buckets   83% 70% 85% 
P9P HDPE (#2) - Other 
Rigid Items 
(including 
containers)   89% 100%  100%  
P10P  HDPE (#2) - 
Flexible and Film 
Items   30% 37% 60% 
P11P  PVC (#3) - Rigid 
Items   94% No Evidence of 
Sorting  No Evidence of 
Sorting  
P12P  PVC (#3) - Flexible 
and Film Items   12% 37% 60% 
P13P  LDPE (#4) - 
Bottles, Jugs , and 
Jars  94% No Evidence of 
Sorting  No Evidence of 
Sorting  
P14P  LDPE (#4) - Other 
Rigid Items   80% No Evidence of 
Sorting  No Evidence of 
Sorting  
P15P  LDPE (#4) - Clear 
Non-Bag Film  6% No Evidence of 
Sorting  No Evidence of 
Sorting  
P16P  LDPE (#4) - Other 
Flexible and Film 
Items   12% 37% 60% 
P17P  PP (#5) - Bottles, 
Jugs , and Jars   94% 80% 89%  
Staff Report      14 
 
Category 
ID Covered Material 
Category (CMC)  Percentage of 
Population with 
Collection of 
CMC for 
Recycling  Percentage of 
Surveyed 
Counties 
Served by 
MRFs 
Recovering 
CMC  Percentage of 
Surveyed 
Population 
Served by 
MRFs 
Recovering 
CMC  
P18P  PP (#5) - 
Thermoformed 
Containers, Cups, 
Lids, Plates, 
Trays, Tubs   82% 80% 89% 
P19P  PP (#5) - Utensils   17% 80% 89% 
P20P  PP (#5) - Other 
Rigid Items   75% 80% 89% 
P21P  PP (#5) - Clear 
Non-Bag Film   21% No Evidence of 
Sorting  No Evidence of 
Sorting  
P22P  PP (#5) - Other 
Flexible and Film 
Items   27% 37% 60% 
P23P  PS (#6) - 
Expanded/Foamed 
Hinged 
Containers, Plates, 
Cups, Tubs, Trays, 
and Other Foamed 
Containers   78% No Evidence of 
Sorting  No Evidence of 
Sorting  
P24P  PS (#6) - 
Expanded/Foamed 
Cushioning and 
Void Fill   7% No Evidence of 
Sorting  No Evidence of 
Sorting  
P25P  PS (#6) - Other 
Expanded/Foamed 
Forms   7% No Evidence of 
Sorting  No Evidence of 
Sorting  
P26P  PS (#6) - Solid 
Hinged 
Containers, Plates, 
Cups, Tubs, Trays, 
and Other Solid 
Containers   78% No Evidence of 
Sorting  No Evidence of 
Sorting   
Staff Report      15 
 
Category 
ID Covered Material 
Category (CMC)  Percentage of 
Population with 
Collection of 
CMC for 
Recycling  Percentage of 
Surveyed 
Counties 
Served by 
MRFs 
Recovering 
CMC  Percentage of 
Surveyed 
Population 
Served by 
MRFs 
Recovering 
CMC  
P27P  PS (#6) - Utensils   1% No Evidence of 
Sorting  No Evidence of 
Sorting  
P28P  PS (#6) - Other 
Solid Forms   92% No Evidence of 
Sorting  No Evidence of 
Sorting  
P29P  PS (#6) - Flexible 
and Film Items   12% 37% 60% 
P30P  Plastics and 
Polymers 
Designed for 
Potential 
Compostability - 
Rigid Items   0% 27% 48% 
P31P  Plastics and 
Polymers 
Designed for 
Potential 
Compostability - 
Flexible and Film 
Items   0% 27% 48% 
P32P  Multi -Material 
Laminate - Mailing 
Pouches & 
Shipping 
Envelopes   0.3% No Evidence of 
Sorting  No Evidence of 
Sorting  
P33P  Multi -Material 
Laminate - Other 
Forms   0% No Evidence of 
Sorting  No Evidence of 
Sorting  
P34P  Other/Mixed 
Plastics - Textiles   0.5% No Evidence of 
Sorting  No Evidence of 
Sorting  
P35P  Other/Mixed 
Plastics - Rigid 
Items   89% 27% 48%  
Staff Report      16 
 
Category 
ID Covered Material 
Category (CMC)  Percentage of 
Population with 
Collection of 
CMC for 
Recycling  Percentage of 
Surveyed 
Counties 
Served by 
MRFs 
Recovering 
CMC  Percentage of 
Surveyed 
Population 
Served by 
MRFs 
Recovering 
CMC  
P36P  Other/Mixed 
Plastics - Flexible 
and Film Items   12% 37% 60% 
P37P  Plastic - Small - 
No side greater 
than 2”   94% No Evidence of 
Sorting  No Evidence of 
Sorting  
WO1N  Wood - All 
Untreated Forms 
w/o plastic 
component   0% No Evidence of 
Sorting  No Evidence of 
Sorting  
WO1P  Wood - All 
Untreated Forms 
w/ plastic 
component   0% No Evidence of 
Sorting  No Evidence of 
Sorting  
WO2N  Wood - All Treated 
or Painted Forms 
w/o plastic 
component   0% No Evidence of 
Sorting  No Evidence of 
Sorting  
WO2P  Wood - All Treated 
or Painted Forms 
w/ plastic 
component   0% No Evidence of 
Sorting  No Evidence of 
Sorting  
WO3N  Other/Mixed 
Organic - Textiles 
w/o plastic 
component   0.5% No Evidence of 
Sorting  No Evidence of 
Sorting  
WO3P  Other/Mixed 
Organic - Textiles 
w/ plastic 
component   0.5% No Evidence of 
Sorting  No Evidence of 
Sorting  
WO4N  Other/Mixed 
Organic - Other 
Forms w/o plastic 
component   0% No Evidence of 
Sorting  No Evidence of 
Sorting   
Staff Report      17 
 
Category 
ID Covered Material 
Category (CMC)  Percentage of 
Population with 
Collection of 
CMC for 
Recycling  Percentage of 
Surveyed 
Counties 
Served by 
MRFs 
Recovering 
CMC  Percentage of 
Surveyed 
Population 
Served by 
MRFs 
Recovering 
CMC  
WO4P  Other/Mixed 
Organic - Other 
Forms w/ plastic 
component   0% No Evidence of 
Sorting  No Evidence of 
Sorting  
WO5N  Wood & Other 
Organic Materials - 
Small - No side 
greater than 2” w/o 
plastic component   0% No Evidence of 
Sorting  No Evidence of 
Sorting  
WO5P  Wood & Other 
Organic Materials - 
Small - No side 
greater than 2” w/ 
plastic component   0% No Evidence of 
Sorting  No Evidence of 
Sorting  
   
Staff Report      18 
 
Methods, Assumptions, and Limitations  
This section covers the methods used to evaluate, survey, visit, and conduct materials 
characterization studies of large volume transfer processors that have been identified as 
serving  recycling programs  for jurisdictions . 
Methods  
CalRecycle conducted two primary data collection efforts to provide information on the 
two criteria outlined in PRC 42355.51(d)(2). First, data collection was conducted to 
gather information on material types and forms collected for recycling by jurisdicti on 
recycling programs. Second, data collection was conducted to gather information on 
material types and forms that are recovered by large volume transfer/processors 
(LVTPs) in California.   
The following methods are provided separately for each of the two data collection 
efforts . For more detailed information on the data collection efforts described below, 
including the limitations of data collection, see the SB 343 Preliminary Findings report . 
Materials Collected by Jurisdiction Recycling Programs  
To identify  which recyclable materials are being accepted across the state  by 
jurisdiction recycling programs , local recycling information was collected for jurisdiction s 
in California. Using population data combined with available  information on materials 
accepted by jurisdiction curbside recycling programs, CalRecycle estimated the 
proportion of the statewide population that accepts a given CMC  for recycling collection.  
To obtain the most detailed information available  on materials collected by jurisdiction 
recycling programs, CalRecycle staff searched  for information provided to the public by 
the jurisdictions or haulers on the materials that are  collected for recycling in their 
residential curbside collection programs for all listed jurisdictions and unincorporated 
areas in California . The iR ecycle Smart.com website was used as a starting point to 
access recycling information for each jurisdiction. Information was found for every 
jurisdiction except for Trinity County a nd Tulelake City. 
CalRecycle staff  recorded which materials  were accepted by, and explicitly not 
accepted by, each jurisdiction’s  recycling program . Jurisdiction guidance on materials 
accepted for recycling often utilized broad and easy -to-understand terms (e.g., plastic 
food and beverage containers ). Material types reported by jurisdictions were 
standardized under general material types of glass, metal, fiber, plastics, and 
miscellaneous . Each general material type was further separated into sub -categories,  
Staff Report      19 
 
with a list of 89 unique categories established for materials commonly accepted for and 
excluded from recycling collection.  
For jurisdictions with mixed waste collection (e.g., trash and recyclables are collected 
together in one bin), it was assumed that all materials were accepted for recycling 
collection unless the jurisdiction provided information to the public on which mate rials 
were specifically being collected for recycling.  
The standardized categories of materials accepted by jurisdiction recycling programs 
were then aligned to the list of SB 54 CMCs.  For example, if a jurisdiction  collected  
“glass bottles,” it was indicated  that the jurisdiction  collect ed two CMCs : (1) Glass 
Bottles and Jars without a plastic component ; (2) Glass Bottles  and Jars with a plastic 
component.  A list was generated  of which CMCs  each jurisdiction  collected  for 
recycling . Staff then estimated  the proportion of the statewide population with access to  
curbside recycling collection for each CMC  by dividing the summed populations of the 
jurisdictions that accepted an item for recycling by the total population of California.   
Materials Recovered by Large Volume Transfer/Processors 
(LVTPs)  
Using a combination of surveys, facility visits, and material sorting at LVTPs, 
CalRecycle estimated the proportions of the (1) state’s recycling programs and (2) 
statewide population, that are served by LVTPs sorting covered material categories into 
defined strea ms for recycling processing.  
Large Volume Transfer Processor Surveys & Facility Visits  
Using information from CalRecycle’s Solid Waste Information System  (SWIS)  and 
outflow data from CalRecycle’s Recycling and Disposal Reporting System  (RDRS), 
CalRecycle created a list of 50 facilities that were permitted LVTPs with average 
quarterly potential reuse outflows of over 4,000 tons.  
CalRecycle developed phone and on -site surveys to collect information from the 
identified LVTPs sorting recyclable materials. Questions covered topics including basic 
facility information, facility capacity, inflows and material origins, outflows and types  of 
material aggregated for sale, and technologies deployed at the facility. CalRecycle 
performed phone surveys with 37 LVTPs. Eight of the surveyed facilities did not perform 
material sorting activities on -site and were removed as facilities of interest. The 
surveyed facilities that perform material sorting activities onsite serve counties that 
make up 88.5% of the population of the state.  
CalRecycle staff conducted  more in -depth  in-person surveys with 24 of the 37 facilitie s, 
which included tours of the sorting activities  and discussions on topics such as  
Staff Report      20 
 
contamination, bale destinations , and origins of processed material. For each facility, 
information was gathered on the types of materials that were processed and aggregated 
for sale by LVTPs.  
Large Volume Transfer Processor Material Characterization Study  
From the 37 surveyed facilities , 10 facilities  were selected for sampling  and sorting in 
August 2023 . Facilities were classified by five regions (Central Valley, Coastal, Los 
Angeles and San Diego Basins, Mountain , and San Francisco Bay Area) for 
representative sampling of focal regions.  Facilities were selected to maximize 
representative sampling by geography and population density.  
The 10 facilities were distributed as follows among the regions of California:  
1.) Mountain – 1 facility  
2.) Central Valley – 3 facilities  
3.) San Francisco Bay Area – 3 facilities  
4.) Coastal – 1 facility  
5.) Los Angeles and San Diego Basins – 2 facilities  
A contractor, with oversight from CalRecycle staff, conducted sampling and sorting at 
the 10 facilities. Samples were collected from post -sort outflows, meaning that material 
would not undergo further processing at that facility. Sampled outflows were materials 
aggregated fo r sale or for further processing at another facility. Residual outflow 
destined for disposal was also sampled.  
Materials greater than two inches were sorted into 91 material categories based on 
material type and form. Weight (in pounds) was obtained for the unsorted sample and 
each sorted category. In total, 196 hand -sorted samples  and 70 visually characterized 
samples were taken  from 10 facilities  in August 2023 . 
Estimating Proportions of Covered Material Categories  Sorted into Defined 
Streams by LVTPs  
CalRecycle estimated the percentage of the state being served by LVTPs sorting each 
CMC  into defined streams for recycling processing. Using survey and sorting data, 
CalRecycle staff estimated the percentages in terms of (1) the proportion of state’s 
recycling programs (at the county level) and (2) the proportion of the statewide 
population,  served by those LVTPs.  
Data from the sampling and sorting was used to determine whether CMCs  were 
predominantly ending up in defined streams, meaning the materials  were being 
processed for sale or further processing. Hand sort data as well as visual 
characterization data was used to: (1) identify which outflows each CMC  was found in;  
Staff Report      21 
 
and (2) estimate the proportion of that CMC  that ends up aggregated for 
sale/processing compared to disposed.  
To avoid counting a contaminant as material sorted into a defined stream , criteria were 
established to identify when the presence of a CMC  in an outflow was acceptable or 
likely to be a contaminant. For example, plastic items were commonly found in defined 
streams for metal and paper. The plastic items are likely a contaminant and not a target 
material for those defined streams. If any of the  established  criteria were not met, the 
presence of that CMC  in that defined stream  was not considered.  
Survey data indicated which of 27 survey facilities had each defined stream present, as 
well as which jurisdictions each survey facility serves. This produced the list of counties 
served by facilities with defined streams available for each CMC . 
Assumptions  
In order to evaluate the recyclability of CMCs  based on the collection and processing 
criteria established by SB 343, several assumptions were necessary.  For assumptions 
related to the collection of information used to evaluate the recyclability of CMCs , 
please refer to the report published pursuant to PRC Section 42355.51(d)(1) (B). 
Material Categories  
Data collected by CalRecycle pursuant to PRC Section 42355.51(d)(1)(B) was planned 
and executed prior to the development and finalization of the CMC list required by 
SB 54 (PRC Section 42061(a)(1)). Additionally, information regarding what materials 
are accepted by jurisdiction recycling programs typically only identifies material types at 
a high level and is generally not specific to the form of the materials.  
The data collected pursuant to PRC section 42355.51(d)(1)(B) was extrapolated to 
evaluate the status of CMCs relative to the requirements of PRC section 
42355.51(d)(2)(A) and 42355.51(d)(2)(B)(i).  An index of how the information collected 
pursuant to SB 3 43 was applied to the draft CMC list is included in the report published 
pursuant to 42355.51(d)(1)(B) . 
Recycling Programs for Jurisdictions  
Recycling programs for jurisdictions are assumed to be jurisdiction residential curbside 
collection programs for the purpose of evaluating the portion of the population that has 
collection services that accept different materials.  
Data on the jurisdictions from which LVTPs are receiving recyclable materials for 
processing is limited. To utilize available information, the percentage of recycling 
programs served by LVTPs that meet PRC Section 42355.51(d)(2)(B)(i) is estimated by  
Staff Report      22 
 
calculating the percentage of California counties that send the CMC to LVTPs that 
recover that CMC.  
Large Volume Transfer/Processors Servicing Percentage of 
Recycling Programs  
Data collection conducted pursuant to 42355.51(d)(1)(B) identified 27 LVTPs that 
process significant quantities of recyclable materials and send those materials in 
defined streams for further processing and reclaiming.  Additional information indicates 
that those 27 LVTPs accept material from 30 counties, or approximately 53% of 
counties.  
In order to evaluate what materials are being collected by statewide curbside collection 
programs and recovered by material recovery facilities that collectively serve at least 60 
percent of those collection programs, the data collected from the 27 LVTPs i s assumed 
to be representative of statewide recyclable material processing infrastructure.  
Limitations  
The data collected pursuant to SB 343 has the following limitations with respect to 
evaluating the recyclability of CMCs pursuant to 42355.51. For limitations related to the 
collection of information used to evaluate the recyclability of covered materials,  please 
refer to the report published pursuant to PRC Section 42355.51(d)(1) (B). 
Information presented in this report is based on the current existing, known, and 
available information and statutory language, which are subject to change.  
Product or material specific criteria  
SB 343 and Title 14, Section 17989.2 of the California Code of Regulations  establish 
material specific criteria for recycling labeling, which are referenced by SB 54 for the 
purpose of determining a list of CMCs that are deemed recyclable.  CalRecycle is 
unable to make a determination of recyclability based on product specific c riteria and 
can only evaluate if the CMC meets the requirements established by 42355.51(d)(2).    
Staff Report      23 
 
Abbreviations and Acronyms  
CMC(s)  - Covered Material Category(ies)  
EPR  - Extended Producer Responsibility  
LVTP(s)  - Large Volume Transfer/Processor(s)  
MCS   - Material Characterization Study  
PRC   - Public Resources Code  
RDRS   - Recycling and Disposal Reporting System  
SB 343  - Senate Bill 343 (Allen, Chapter 507, Statutes of 2021)  
SB 54   - Senate Bill 54 ( Allen, Chapter 75, Statutes of 2022)  
SWIS   - Solid Waste Information System  