Hitting California’s SB 54 recycling targets for cartons and cups through single-stream collection could push roughly 100,000 tons of new plastic contamination into the state’s exported paper bales each year, a panelist said during a panel at the California Resource Recovery Association’s San Diego conference.
Martin Bourque, executive director of Berkeley’s Ecology Center, was one of five panelists discussing how to spend SB 54 money on building out recyclability for flexible film and cartons.
He opened by telling the room that what he had to say “may be disturbing” to anyone whose recycling contract depends on paper revenue.
Emily Coven, California executive director of Circular Action Alliance, offered some nuance on the material itself.
“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 are much further behind.
Katherine Huded, director of strategic engagement at The Recycling Partnership, pointed to CalFlex’s own pilot as evidence the state isn’t moving blind.
“We’ve put bins on the ground to more than 600 households,” she said, describing a source-separated collection pilot funded by CAA and run with the San Jose Conservation Corps. The program is still collecting data on what residents put in the bins, and whether the resulting stream is clean enough to sell.
The ‘dirty decade,’ revisited
Bourque traced his warning back to what he called “the dirty decade,” or the years before China’s 2018 National Sword policy shut off export markets for mixed plastics. The plastics industry had pushed municipalities to collect mixed plastics on the promise that volume alone would create market value, he said.
Communities baled and exported the material, mostly to China. A significant share was never actually recycled. It was dumped, burned or otherwise disposed of near the communities receiving it, while US programs counted it as diversion.
When National Sword hit, “we paid the price, not the plastics industry,” Bourque said. Recycling economics for cities nationwide were upended. Programs lost residents’ trust.
The disruption also shows up in the trade data. US recovered paper exports to China fell from 15.7 million metric tons in 2015 to zero by 2021, according to trade figures compiled by Tissue World Magazine.
The same collapse pushed California’s paper markets toward Vietnam and Thailand. A University at Buffalo study published in the journal Sustainability found the volume of plastic landfilled in the US rose 23.2% after National Sword took effect, even after accounting for oil prices and other market factors. One MRF the researchers interviewed had to slow its sorting line by 40% and roughly doubled its operating costs.
Film and cartons follow the same two-dimensional path as paper through a MRF, Bourque said, instead of sorting with cans and bottles. Even multimillion-dollar optical sorters built to clean incidental film and cartons off paper lines can’t hit international quality standards without added bale grooming and staffing, he said.
The 100,000-ton estimate
Of the 5 million metric tons of recovered paper exported from California in 2025, 85% went to Thailand, Vietnam, Malaysia and Taiwan, according to US International Trade Commission data.
By comparison, CalRecycle’s own 2024 State of Disposal and Recycling report shows that roughly 31% of all recycled material generated statewide — not paper specifically, but every material combined — is exported overseas (10.2 million tons of the 32.4 million tons recycled).
Nationally, wastepaper exports have followed a similar shift. India is now the top US destination, followed by Malaysia, Thailand and Vietnam, according to a March 2026 USITC analysis. China’s share, 23% of US exports as recently as 2020, has fallen to about 2.5% since Beijing’s import restrictions took effect.
Even if bales met specifications today and carried just 2% plastic contamination, that’s still about 100,000 tons of plastic embedded in California’s exported recovered paper every year. Overseas, that plastic may be dumped, openly burned, diverted into other manufacturing or burned in mills with lower emissions standards than in the US, Bourque said.
He pointed to reporting on Tropodo, Indonesia, where commercial kitchens burn imported plastic waste to fuel tofu production. That study found dioxin in eggs from chickens raised near the kilns at levels among the highest ever recorded in Asia, second only to samples collected near a former US air base in Vietnam contaminated by Agent Orange.
Can we, or should we?
Bourque is a founding member of the Alliance of Mission-Based Recyclers. The group applies a two-part test to any material being considered for the recycling stream, he said: Can it be collected, sorted and marketed, and separately, should it be? For flexible film today, he said the answer to the first question is no.
SB 54 itself asks a version of that second question. The law defines a “responsible end market” as one where the recycling of materials and disposal of contaminants is “conducted in a way that benefits the environment and minimizes risks to public health and worker health and safety.”
Material sent to landfill, incineration or similar processes doesn’t count as recycled, under the law’s 65% recycling-rate calculation.
The Flexible Film Recycling Alliance’s first Impact Report, released in January 2026, put the US film recycling rate at just 9.4%, with only 0.5 million of an estimated 5.3 million tons of recyclable flexible packaging actually getting recycled each year.
In California specifically, a needs-assessment figure cited at a June 2026 industry summit put the state’s film recycling rate at roughly 5%, or 66 million to 70 million pounds.
Materials that do clear collection and sorting hurdles should still meet a higher bar, Bourque argued, one that weighs whether the net environmental and economic effect is positive and financially sustainable.
As alternatives, Bourque pointed to mail-back programs and source-separated collection: paying residents directly for clean film, which he said could cost several dollars a pound to collect and process, against roughly a dime a pound for paper. He cited pilot projects at Eureka Recycling’s test facility in Minneapolis pricing incidental film collection in that range.
When asked what California could learn from EPR programs already running elsewhere, Bourque pointed to Canada.
“We watch Canada pretty closely, and I would call that like ‘yikes,'” he said.
Canada’s program was forced to move fast by mandate and “we’re in that same boat as Canada in many regards.”
Many jurisdictions with packaging EPR also require source separation, he noted, putting them in a better position than California to get a clean film stream.
