Editor’s note: This is the third installment of a three-part Policy Now series on SB 54 implementation covering the local collection deadline and exemption process, responsible end markets and reimbursement funding, as well as packaging progress, challenges and opportunities under SB 54.
Carton recycling has crossed a threshold that flexible film is nowhere near reaching, and that gap is shaping how California’s Circular Action Alliance (CAA) is spending SB 54 money in 2027.
That contrast anchored a facilitated roundtable on challenged and not-yet-recyclable materials at the California Resource Recovery Association’s San Diego conference. Panelists examined materials at different stages of recyclability under SB 54. CalRecycle approved permanent regulations for the law in May.
Access to recycling for cartons now reaches 74% of California households, and sorting capability is at 62% of the state’s recycling programs, according to Jordan Fengel, president of the Carton Council.
Both figures clear the thresholds SB 343 requires before a material can carry the “chasing arrows” recyclability label of 60% collection access and 60% sortation access statewide.
Fengel said that’s a shift from where the industry started. The Carton Council formed in 2008, when national household access to carton recycling was around 18% and the national recycling rate was about 6%.
Fengel pointed to a new in-state market at a former General Mills cereal plant in Lodi, California. He said the site processes 750 tons of cartons a month into a gypsum-alternative board used in Amazon warehouses and Tesla’s Gigafactories.
He called it an example of an open-loop circular economy, noting the boards have an estimated 35-year lifespan. Deconstruction ordinances already adopted in cities including San Antonio, Dallas and Santa Rosa could eventually route torn-down buildings’ board material back into the recycling stream, he added.
He also pointed to a MRF in Oregon that’s installing an optical sorter on its residual line specifically to catch cartons and redirect them back into the fiber stream instead of the landfill. “None of this would be possible without EPR,” Fengel said, relaying the operator’s own assessment of the project.
The film story
Film, on the other hand, tells a different story. California generates roughly 550,000 tons of residential flexible film a year, said Katherine Huded, director of circular ventures at The Recycling Partnership. “It is not currently considered recyclable or on the statewide recyclable list in California,” she said, adding that end markets can currently absorb only about 10% of that volume.
Patrick Keenan, a packaging engineer at General Mills who also served on the SB 54 advisory board, said most large brands are mid-journey on shifting multi-material flexible packaging to single-resin formats like polyethylene or polypropylene. “It’s more costly than what we’d expect the EPR fees to offset,” he said.
“We’re seeing about 50% of people know that alternative collection exists for film,” he added, referring to in-store drop-off bins. “When they know it exists, they use it,” and those bins currently move material to market at a profit.
Emily Coven, CAA’s California executive director, cautioned against treating film as one material.
“We don’t look at it as one big bucket,” she said. “Not all film and flex is created equal.”
Clean commercial PE film, like pallet wrap, already has an established collection and market pathway, she said. Other resin types and multi-material film are much further behind.
Fengel added that the Lodi carton facility is itself already consuming some of that recovered film, about 30% of what goes into its board is mono-material LDPE film pulled from California MRFs, alongside the cartons.
Two funding models
The Recycling Partnership’s CalFFlex initiative has funneled roughly $6 million into eight end markets and is running an on-the-curb collection pilot with more than 600 households, funded by CAA, the latest in a string of California film-collection pilots launched this year.
A parallel effort from the US Flexible Film Initiative (USFFI) pays MRFs a per-pound fee to route “incidental” film, the material consumers already put in curbside bins by mistake, to end markets instead of landfills, then pays a second fee to those markets to cover contamination cleanup.
“We’re talking hundreds of millions of dollars of investment,” Keenan said of the state’s infrastructure needs assessment, adding that roughly 70% of that figure is earmarked for flexible packaging.
Coven said the PRO is testing multiple collection models such as mail-back, drop-off and curbside pilots rather than committing to one statewide approach before the data is in.
“It’s a dial, not a switch,” she said, adding that CAA’s 2027 program plan will lean on waste characterization data to decide what scales. Her stated goal for 2032 isn’t a single collection method but a roster of end markets CAA has vetted and can point to as certified and responsible, so the state can say with confidence where the material actually goes.
Capital investment
As for the “hundreds of millions of dollars” figure, MRFs need capital upgrades to capture film as a sellable bale in the first place, and the equipment varies by facility, Huded said: some need ballistic separators to catch material that tangles in sorting lines, “but also there’s things like film screens, there’s opticals — there’s many different ways to go about it.”
USFFI has already issued an RFP and is finalizing long-term contracts with three California MRFs, each committing to bale incidental film and route it to an end market under a set per-pound price.
Keenan said he couldn’t disclose the figure but said it lines up with the state’s needs-assessment estimate.
Huded said CAA is also weighing that MRF-upgrade-and-subsidy model against the cost of scaling alternative collection outright, an added on-the-curb cart, extra truck routes and pickups to determine which mechanism recovers the most material per dollar spent.
