Don’t Let Film Plastic Unravel California’s Paper Recycling

AMBR is collecting organizational support for a statement to CalRecycle regarding the implementation of SB 54 to ensure California’s high-performing paper and cardboard recycling systems are protected from plastic contamination.

If you are interested in signing on to the below letter, please complete our sign-on form.

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We, the undersigned materials recovery facility (MRF) operators, haulers, paper brokers, exporters, and recycling stakeholders, urge CalRecycle and the Circular Action Alliance to implement SB 54 in a manner that protects California’s high-performing paper and cardboard recycling systems. Specifically, we ask that SB 54 regulations and the Producer Responsibility Organization implementation:

1. Maintain clear separation between paper/cardboard and flexible/film plastic in recycling collection systems;
   
2. Prevent contamination that jeopardizes access to paper/cardboard quality and viable and responsible end markets;
   
3. Ensure producers bear the full and transparent costs associated with adding new materials that degrade or reduce the capture of existing recyclable materials; and
   
4. Reinforce, rather than weaken, the quality and economic viability of paper/cardboard outputs for responsible end markets.

Paper and cardboard are the economic and operational backbone of California’s post-consumer recycling systems. Preserving their quality, market value, and compliance with international trade standards is essential to achieving SB 54’s waste reduction and recycling goals.

Failure to protect fiber markets risks destabilizing one of the only material streams that consistently delivers high recycling rates, reliable end markets, and economic benefit.

This statement urges CalRecycle and Circular Action Alliance to implement SB 54 regulations in a manner that protects our fiber markets from pricing and movement restrictions due to cumulative contamination in the paper and cardboard streams. 

Specifically, we request that flexible plastic and film packaging not be included in curbside collection programs.

California Paper and Cardboard Recycling Background 

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Paper Recycling Works

Paper and cardboard are the foundation of California’s recycling system, recycled at approximately 70%. These materials are universally accepted curbside and readily recycled back into new paper products – a process and supply chain that is reliant on clean feedstocks. 

Over 90% of our paper and cardboard markets are international and covered under strict trade and import/export regulations. Failure to comply with these requirements has resulted in complete market breakdowns, following China’s National Sword policy alongside customs crackdowns, pricing disruptions, returned shipments, and loss of individual markets. Under SB 54, haulers and MRF operators no longer control what must be collected, and may be held responsible for exporting to markets with poor contamination disposal practices, even those deemed by the state or PRO to be “Responsible End Markets.” Due to proprietary brokerage relationships and commingling of shipments from multiple facilities, these markets are often beyond the line of sight of recyclers, putting us at tremendous risk.

Preserving paper and cardboard’s recyclability, market value, and system performance is essential to achieving SB 54’s waste-reduction and recycling objectives. The following points highlight the risks associated with SB 54 rulemaking, considering alternatives for currently non-recyclable flexible plastic and film, and propose a solution to consider separate alternative collection approaches to those involving paper and cardboard. Protecting paper and cardboard recycling supports:

• High recycling rates and the use of recycled content;
• Reduced reliance on virgin raw materials;
• Strong returns to sustain recycling programs and infrastructure; and
• Lower system costs compared to managing problematic materials.

Clean Collections Keep Recycling Costs Low

The most effective way for producers to reduce costs under SB 54 is to design packaging that works in existing recycling and composting systems instead of paying to try to manage waste that cannot be easily recovered.

Keeping paper and cardboard feedstock clean costs less than retrofitting recycling infrastructure or attempting to meet recycling targets for materials that have repeatedly failed to demonstrate this capacity in existing systems.

Producers will face lower EPR fees and fewer operational costs when paper and cardboard is protected from contamination with problematic or hard-to-manage packaging formats like flexible plastic and film.

Producers Must Pay Full Costs

As SB 54’s regulatory framework is based on additionality, the full cost of adding new materials and increasing capture rates through curbside recycling must be borne by producers. This must include any negative cost impacts for paper and fiber materials, such as additional decontamination, quality assurance, revenue losses, disposal, reduced yield, and any regulatory, customs, or legal consequences of adding a new plastic packaging format to the mandatory collection list.

Flexible Plastic and Film are Contamination Threats

Because paper and cardboard provide the economic backbone of many recycling programs, contamination from flex and film directly threatens program revenues, processing efficiency, and financial stability. These formats in particular represent a number of well-documented risks to paper and cardboard recycling:

• Recycling technologies are capable of separating glass, metal, paper, and rigid plastics but due to similar shape and weight, flexible plastic and film are economically impossible to completely separate from paper.
• Film wraps around sorting equipment, causing shutdowns and requiring manual removal.
• Flexible plastic packaging contaminates paper and cardboard bales, lowering quality and value even with high-cost optical sorting and quality assurance staff.
• Contamination in the paper mills typically allows no more than 2% total contamination. This 2% is reached with the incidental contaminants today, and will be alarmingly exceeded should collection programs add flex and film.
• Sorting flex and film carries paper with it, losing valuable fiber and contaminating those flex and film bales.
• There is no responsible end market for contaminated papers. As a result China, Malaysia, Vietnam, South Korea, and Taiwan have banned the import of mixed plastic/paper waste, with other Asian countries setting strict and increasing contamination limits of 2% or less.
• Plastic-contaminated paper bales cannot be legally absorbed by global markets as they fall under the Basel convention. Basel Parties cannot trade Basel-controlled waste with a non-Party country like the U.S. unless there is a separate agreement.
• Plastics removed at the mill may end up burned or dumped in under-regulated industries. These disposal practices should be prevented by responsible end market requirements, further reducing market demand for California’s exports.

SB 54 Rulemaking Must Keep Recycling Real

SB 54 defines recyclability based on actual system performance, not pilot projects, niche markets, or speculative future technologies. Allowing materials that degrade paper and cardboard streams to be treated as recyclable would:

• Undermine high-performing recycling systems;
• Shift costs and risks onto local governments and recyclers; and
• Contradict SB 54’s objectives to improve recycling quality and credibility.