Help California Recycle More Plastic - Not Send It to Landfills

Dear CalRecycle and Governor Newsom,

We are Californians who believe a healthy environment and an affordable life go together. We are part of the Middle 70% — people who don't fit the usual political boxes and who care more about results than about which side an idea comes from. We are not here to fight environmental advocates or industry. We are pragmatic idealists who want SB 54 to succeed, and we write as a third voice in a debate too often defined by its loudest extremes.

We strongly support California's goal of reducing plastic pollution. We want less plastic going into landfills, less oil being drilled out of the ground, and more of our waste turned into useful new materials.

Source reduction and reuse should come first: the cheapest, cleanest package is the one we never need to make. But for the plastic we still use, recycling has to work.

California's landmark recycling law, SB 54, establishes an ambitious goal: recycle 65% of single-use plastic packaging and food service ware by 2032. But traditional mechanical recycling cannot effectively process much of our plastic waste. To reach California's goals, we need chemical recycling too.

Chemical recycling can turn difficult-to-recycle plastic waste back into the raw material for new plastic, called pyrolysis oil (PyOil), which can replace fossil-derived feedstocks. Modern facilities can operate with low emissions, minimal energy consumption, no hazardous waste generation, and substantially lower carbon footprints than conventional oil production.

Importantly, SB 54 already establishes a rigorous process for chemical recycling facilities to qualify as Responsible End Markets (REMs) and demonstrate that they meet environmental and recycling standards.

We support these safeguards. We also appreciate that the October 2026 program plan accepts mass balance accounting with independent verification. But we're concerned that overly restrictive rules for how recycled materials receive credit could still undermine the entire industry.

An Industry We Cannot Afford to Lose

Over the past decade, billions of dollars were invested in a new generation of chemical recycling companies. By the early 2020s, the industry was beginning to thrive, supported by voluntary recycled-content commitments from major consumer brands.

Then many companies scaled back their environmental commitments, and demand for recycled materials collapsed.

We've already seen pioneering recycling companies fail, shut down facilities, or sell assets this year. These companies represent years of innovation, investment, and technical expertise that cannot easily be replaced. Many are independent, small and mid-sized circular businesses — exactly the companies that can turn local waste into local jobs. If we allow this industry to disappear, it could take another generation to rebuild the infrastructure we've already paid to develop.

The industry is now depending on EPR laws like SB 54 to give major manufacturers the confidence to renew their recycling commitments. But those laws must be practical enough for companies to follow.

Two Simple Rules That Make Recycling Work

We ask California to embrace two principles:

1. Mass Balance:Think of it like a bank account. When verified recycled material enters a manufacturing system, companies can account for that material and assign its recycled attributes to eligible products, without following every individual molecule. Independent audits ensure that no more recycled material is credited than actually qualifies and that nothing is counted twice.


2. Free Attribution: Allow companies to purchase credits backed by verified recycling, regardless of which factory receives the recycled material or where the specific molecules ultimately end up. A company helping finance the recovery of plastic waste should be able to receive appropriate credit for that contribution.

Here's why this matters.

Imagine a major petrochemical company making plastic for the shampoo bottles of a household-name consumer products brand. The plastics manufacturer already has enormous manufacturing facilities designed to use particular raw materials. Requiring it to build new infrastructure or fundamentally change its production process just to use a specific batch of recycled oil would be prohibitively expensive.

But auditing the chain of custody of recycled materials and their associated credits is entirely feasible. We can verify how much plastic was recovered, how much PyOil was produced, where it was sold, and ensure that credits are never counted twice.

The solution is to use the industrial infrastructure we already have, while allowing companies to purchase independently verified recycling credits across different facilities and supply chains.

We should track the recycling, not demand that every recycled molecule follow a particular path.

And because credits can travel, a brand anywhere can help finance a small recycler right here in California. That is how a statewide law can grow hyperlocal circular economies: businesses that turn our own waste into feedstock, employ our neighbors, and keep value in our communities instead of shipping it overseas.

Please Make SB 54 Achievable

Mass balance and broad free attribution, working together, offer the best opportunity to achieve widespread industry participation and maximize compliance with SB 54.

If California makes the requirements too expensive or difficult to follow, manufacturers may simply pay compliance fees, pass those costs to consumers, and eventually challenge the law itself. Meanwhile, the innovative companies capable of recycling our plastic waste could disappear.

That would be the worst possible outcome: higher costs, fewer recycling facilities, and more plastic going into landfills.

We urge CalRecycle and the Governor's office to:

• Allow the broadest practical free attribution and mass-balance accounting under SB 54, backed by independent auditing, rigorous REM standards, and safeguards against double counting. These rules should enable verified recycling credits to be purchased and transferred across companies and facilities without requiring physical molecule-by-molecule matching.


• Keep the rules technology-neutral, so every proven method of source reduction, reuse, refill, and recycling can count.


• Measure success by real environmental results, not by fines collected — and publish those results locally, so every community can see how much of its material is actually recycled and where it goes.<

We don't want to weaken California's environmental standards. We want to make sure they work.

About Circle America

We are Californians who believe a healthy environment and an affordable life go together. We are part of the Middle 70% — people who don't fit the usual political boxes and who care more about results than about which side an idea comes from. We are not here to fight environmental advocates or industry. We are pragmatic idealists who want SB 54 to succeed, and we write as a third voice in a debate too often defined by its loudest extremes.

An alliance united by pragmatic idealism - ambitious environmental goals, practical solutions, and a determination to make laws actually work - Circle America is here to help. We are not waiting to be told what to do; we want to be partners in making this law a model for the nation — one that cuts waste, lowers costs, and builds healthy, vibrant communities where people can afford to live well.

Let's protect the recycling innovations we've invested billions to develop, keep plastic out of our landfills, and reduce our dependence on newly drilled oil.

Sincerely,

Sincerely,

[First Name] [Last Name]
[Street]
[City] [State] [Zip]