Rigid Plastic Packaging Container (RPPC) Advisory Opinions

Product manufacturers who have received a Pre-Certification notice from CalRecycle may request written advice about the product manufacturer’s compliance with the RPPC law. Following receipt of a Pre-Certification notice, a product manufacturer has 90 calendar days to submit an Advisory Opinion request.

Product manufacturers who have received a Compliance Certification notice may seek an Advisory Opinion from CalRecycle for RPPCs for products introduced since receipt of the Pre-Certification notice.

Note: Container manufacturers may not request Advisory Opinions as a container manufacturer is not directly responsible for meeting the requirements of the law.

Before Making a Request

CalRecycle developed the Container Determination Tools page to help product manufacturers determine whether their product’s packaging is included in the RPPC program.

After reviewing the Container Determination Tools page, if a product manufacturer’s compliance with the RPPC law is still unclear, consider requesting a written Advisory Opinion. 

Requesting an Advisory Opinion

To respond to an Advisory Opinion Request, CalRecycle must have sufficient and relevant information providing the specific facts related to the question(s) being asked.

Requests can include, but are not limited to, the following information:

  • Contact information for the product manufacturer’s representative.
  • A letter detailing, in a clear and concise manner, the question(s) for which an advisory opinion is needed.
  • A description of the packaging, including (but not limited to):
    • The volumetric capacity, such as ounces or cubic millimeters, expressed by container specifications.
    • The dimensions of the container.
    • The container’s empty weight in grams.
    • The resin(s) of the container. If more than one resin is used, provide clarification as to how and where each resin is used.
    • Were different resins used in the product container previously? If yes, what resin(s) were used and what was the date of the change in resin(s)?
    • Any incidentals or components and their composition. “Incidentals or Components” includes caps, lids, handles, and hinges. These components can be plastic or non-plastic material.
  • A minimum of a 5-by-7-inch picture of the container. The container should fill at least two-thirds of the picture and include a scale, such as a ruler. Do NOT submit physical examples unless specifically requested by CalRecycle.
  • All labeling associated with the specific product.
  • All additional facts and related material that should be taken into consideration as they relate to the question being asked. These materials can include, but are not limited to:
    • Date(s) container was manufactured.
    • Date(s) the product was first sold or offered for sale within California within the container.
    • If claiming source reduction:
      • Date of reduction.
      • Container weight before and after reduction.
      • Resin type before and after reduction.
    • If claiming that the product is exempt:
      • Explain how the product/RPPC is exempt.
      • Specific statutory and/or regulatory references to support any claim of exemption.
      • Include any registrations, licenses, and certifications.
      • Other supporting studies related to the RPPC.
  • Any other information the product manufacturer may deem necessary for CalRecycle to consider as it relates to the packaging in question.

Advisory Opinion Request Submittal

The complete request must be submitted to CalRecycle’s Legal Office within 90 calendar days of the product manufacturer receiving either an RPPC Pre-Certification or Compliance Certification notice.

The Advisory Opinion Request should be emailed or sent to:
CalRecycle
RPPC Advisory Opinion
P.O. Box 4025, MS 10A-17
Sacramento, CA 95812-4025

CalRecycle will respond to all written product manufacturer advisory opinion requests within 90 calendar days of receiving a request submitted as described above.

This page provides a brief overview and is not intended to provide a comprehensive list of legal requirements. Please refer to statute and regulations for a complete list of requirements. Users are encouraged to seek the assistance of legal counsel to comply with applicable state law based on their pertinent facts and circumstances.

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Phone: (916) 341-6717  |   Email: RPPC@calrecycle.ca.gov  |  Fax: (916) 319-7337