Rigid Plastic Packaging Containers (RPPC)

Compliance Requirements

• What Is a Rigid Plastic Packaging Container (RPPC)?
• Compliance Options
• Corporate Averaging
• Recyclable vs. Compliant
• Exempt RPPCs

What is a rigid plastic packaging container?

Currently, the California Code of Regulations (CCR) defines RPPCs as containers that:

• Are made entirely of plastic, except for lids, caps, or labels.
• Have a capacity of at least 8 fluid ounces but no more than 5 gallons, or the equivalent volumes.
• Can maintain their shape while holding a product.
• Are capable of multiple reclosures, and are sold with an attached or unattached lid or cap.

RPPCs are not...

• Containers/blister packaging that cannot be reclosed.
• Flexible packages that do not maintain their shape while holding a product.
• Service packages that are filled at the point of sale and do not normally store a product for seven days.
• Plastic boxes that have at least one side that is not made of plastic.
• Plastic buckets with an attached metal handle.

Compliance Options

• Containers which are made from at least 25 percent postconsumer resin.
• Containers which are source-reduced (light-weighted) by 10 percent.*
• Containers which are reused or refilled at least five times.**
• Containers which have a recycling rate of 45 percent if it is a brand-specific or a particular type of RPPC.***

*The source-reduced option requires that packaging changes do not adversely affect the potential for the rigid plastic packaging container to be recycled or to be made of postconsumer material; pursuant to Title 14 CCR 17943(b)(31).
**The reuse or refill option requires supplemental information; pursuant to Title 14 CCR 17946.5(3).
***The 45 percent option requires the product manufacturer to perform calculations; pursuant to Title 14 CCR 17946.5(5).

Corporate Averaging

A product manufacturer may demonstrate compliance by separately "averaging" the postconsumer content, the source reduction, or the refill or reuse data of its containers (Title 14 CCR 17946.5). An average may be calculated using either data specific to containers sold in California, or nationwide. Averaging may be based on an entire product line or sub lines, but it can only include regulated RPPCs for which the same compliance option is claimed. Every regulated RPPC must be included in the "average" or on its own meet one of the compliance options. Nonregulated or exempt RPPCs cannot be included when calculating the average. Averaging must be calculated by the product manufacturer.

Recyclable vs. Compliant

The use of resins that are recyclable is recommended, however compliance with the RPPC law is based on whether or not the container includes 25 percent postconsumer resins in its total weight, has been source-reduced (light-weighted) by 10 percent, or has a recycling rate of 45 percent if it is a brand-specific or a particular type of RPPC. A container that is recyclable, unless it also meets one of the compliance options, would not be compliant with the RPPC law.

Exempt RPPCs

Pursuant to Public Resources Code (PRC) section 42340, some RPPCs are exempt from demonstrating compliance with this law. These include containers:

• Produced in or outside of California that are destined for shipment outside California and that remain with the products upon shipment.
• Specifically used for shipping drugs, medical devices, cosmetics, food, medical food, or infant formula as defined by the Federal Food, Drug, and Cosmetic Act.
• Specifically used for shipping toxic or hazardous products regulated by the Federal Insecticide, Fungicide, and Rodenticide Act.
• Manufactured and specifically used for shipping hazardous materials that are prohibited by federal law from being manufactured with "used material" (postconsumer resin) 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.

Last updated: January 09, 2008