IDFA Seeks Temporary Exemptions from California's SB 54 for Dairy Plastics
The International Dairy Foods Association (IDFA) has approached California's Packaging Producer Responsibility Advisory Board with a proposal to temporarily exclude dairy packaging plastics from the recycling targets set by SB 54. The law mandates a 25% reduction in single-use plastics, 100% recyclability or compostability of packaging, and aims for a 65% recycling rate by 2032.
Danielle Quist, the IDFA's vice-president of regulatory affairs and counsel, testified that many standard materials used in dairy packaging would struggle to meet the law's short-term recycling and source reduction requirements. The IDFA has also requested a three-year waiver from producer responsibility organization-level rules concerning source reduction of plastics in dairy packaging.
The association highlights that packaging types like high-density polyethylene, polyethylene terephthalate, and polypropylene are recyclable but currently do not meet the recycling rate levels under SB 54. Flexible films and other less recyclable materials require a longer transition period to comply with the state's standards.
Quist emphasized that dairy products are perishable, and their packaging must meet stringent food safety and quality criteria, limiting options for packaging reduction at the source. She also expressed concerns about using a 2023 baseline for source reduction, which may not account for increased sales of dairy products that use plastic packaging.
If approved, these exemptions could provide temporary relief from enforcement measures or material bans for materials that fail to meet statutory recycling and source reduction targets. The IDFA also advocates for keeping post-consumer recycled content as a compliance option when supply becomes adequate for dairy packaging needs.
Quist stated, "The timeline for meeting SB 54’s performance goals is out of step with current market and recycling system realities. The proposed temporary exemptions are necessary to give producers and CAA additional time to meet SB 54’s requirements in a more practical and achievable way while continuing to protect safe, nutritious and highly perishable dairy foods."
