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Rigid Plastic Packaging Containers

California’s Rigid Plastic Packaging Container Act, passed in 1991, requires that every rigid plastic packaging container (RPPC) offered for sale in this state meet one of several criteria designed to reduce the amount of plastic being landfilled.

This fact sheet clarifies what is and isn’t an RPPC, who must comply with the law and how compliance is determined.

What is a rigid plastic packaging container (RPPC)?

A rigid plastic packaging container…

• Is made entirely of plastic, except for lids, caps, or labels.
• Is capable of multiple reclosures, with an attached or unattached lid or cap.
• Can maintain its shape while holding a product.
• Contains at least 8 fluid ounces but no more than 5 gallons, or the equivalent volumes.
• Is normally used to store a product for seven days or longer (from the time the container is filled).

RPPCs are not:

• Blister packaging that cannot be reclosed.
• Clamshells that cannot be reclosed.
• Flexible tubes.
• Service packaging that does not normally store a product for seven days.
• Plastic boxes that have at least one side or attached lids that is not made of plastic.
• A blister package that has at least one attached component not made of plastic.
• Any plastic container that cannot hold at least 8 fluid ounces, or the volumetric equivalent.
• Any plastic container that can hold more than 5 U.S. Gallons or the volumetric equivalent.

Who must comply?

A company must comply with the law if it manufactures, distributes, or imports a product that is packaged in a “rigid plastic packaging container,” and is sold or offered for sale in California, and if its company name is on the container label.

How is compliance determined?

As of 1995, rigid plastic packaging containers sold or offered for sale in California are required to meet one of the following criteria:

• Have a recycling rate of 25 percent, based on annual reports published by the IWMB.
• Have a recycling rate of 55 percent if its primary material is PETE, based on annual reports published by the IWMB.
• Have a recycling rate of 45 percent if it is a brand-specific RPPC.
• Be made from at least 25 percent postconsumer resin.
• Be source reduced or “lightweighted” by 10 percent.
• Be reusable or refillable at least 5 times.

If the recycling rates don’t meet the mandated levels of 25 percent and 55 percent, then the IWMB may ask regulated companies to demonstrate compliance through a certification process.

Are there any exemptions from the certification process?

Some RPPCs are exempt from the certification process. These include:

• Containers produced in or outside of California that are destined for shipment outside California and that remain with the products upon shipment.
• Containers used to hold drugs, medical devices, cosmetics, food, medical food, or infant formula as defined by the Federal Food, Drug, and Cosmetic Act.
• Containers used to hold toxic or hazardous products regulated by the Federal Insecticide, Fungicide, and Rodenticide Act.
• Containers manufactured for the purpose of shipping hazardous materials, and that are prohibited by federal law from being manufactured with used material by federal packaging material specifications, or are subject to specified federal testing standards, or to which recommendations of the United Nations on the transport of dangerous goods are applicable.

Must every RPPC meet one of the compliance criteria?

It is not necessary for each RPPC to individually meet one of the compliance criteria. A company may achieve compliance by “averaging” the recycling rates, the postconsumer content, the source reduction or the refill or reuse data of its containers.

An average may be calculated using either data specific to containers sold and recycled in California, or nationwide. Averaging may be based upon an entire product line or sublines, but it may only include RPPCs for which the same compliance criteria are claimed. Every RPPC must be included in the “average” or comply with one of the other criteria.

For more information:

For information on plastics, please visit http://www.calrecycle.ca.gov/Plastics/rppc

Questions?

Call the Integrated Waste Management Board at (916) 341-6518 and ask to speak to one of the staff about recycling rates, compliance and enforcement of the RPPC law, or to get on a mailing list for information on upcoming conferences and workshops regarding plastics.

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