California SB 343: What It Means and How to Comply

SB 343 has a direct impact on companies that manufacture, source, or sell packaged products in California:

• Labeling Risk: Misuse of recyclability claims may lead to regulatory enforcement, legal exposure, or required label changes.
• Design Constraints: Packaging design decisions must now consider end-of-life recyclability in California—not just theoretical recyclability.
• Supply Chain Alignment: Suppliers, converters, and packaging partners must provide accurate material data and recyclability validation.
• Increased Scrutiny: Claims such as “recyclable,” “widely recyclable,” or use of the chasing arrows symbol are now regulated and must be substantiated.

Under California Public Resources Code §42355.51, a product or package can only be labeled as “recyclable” in California if it meets specific statutory criteria. These requirements emphasize actual recycling system performance rather than theoretical recyclability.

1. Collection Coverage (≥60% Population): The material must be accepted for collection by recycling programs that collectively serve at least 60% of the California population. This ensures the material is broadly accessible within existing curbside or equivalent systems.
2. Sorting and Processing Capability: The material must be effectively handled by downstream recycling infrastructure:
   • Sorting Requirement: Must be sorted into defined recycling streams by large-volume transfer or processing facilities. These facilities must collectively serve at least 60% of statewide recycling programs.
   • Reclamation Requirement: Sorted materials must be sent to reclaimers and successfully reprocessed into usable raw materials. Reclamation must be conducted in a manner consistent with international standards (e.g., Basel Convention principles).
3. Composition and Design Compliance: The product or packaging must meet specific material composition and design criteria. It must not include features that inhibit recyclability, such as:
   • Incompatible material combinations
   • Problematic coatings, liners, or additives
   • Components that interfere with sorting or reprocessing

Alternative Qualification Pathways: Outside of the 3 requirements noted above, a product may also qualify as recyclable if it meets any of the following additional provisions:

Recycling Rate Criteria (PRC §42355.51(d)(4)): Demonstrates a sufficiently high, validated recycling rate.

Non-Curbside Collection Programs (PRC §42355.51(d)(5)): Is collected through established non-curbside systems (e.g., take-back programs) with proven effectiveness.

Compliance with Other Applicable Laws (PRC §42355.51(d)(6)): Meets recyclability requirements defined under other governing regulations or statutes.

Step 3: Check Composition and Design Compliance

While SB 343 does not prescribe detailed design specifications for each individual product type, it requires that packaging does not include features that inhibit recyclability within the existing system. In practice, the design must align with how materials are collected, sorted, and reprocessed in California.

A tinplate (steel) aerosol can generally aligns well with SB 343 Requirement 3 when manufactured according to the following requirements:

• Material Stream Compatibility: Steel aerosol cans are part of the ferrous metal recycling stream, which is widely sorted using magnetic separation.
• Internal Coating: Epoxy or polymer linings are commonly used to protect contents. These coatings must:
  • Burn off cleanly during the steel recycling process
  • Not introduce contamination to the melt
• Valve and Actuator System: Typically includes mixed materials (plastic, rubber, metal). These components are acceptable if:
  • They do not interfere with magnetic separation
  • They are removed or managed during reprocessing
• Labeling and Decoration: Printed coatings or shrink sleeves should not hinder identification or create excessive residue during recycling.

Overall Assessment: When designed with compatible coatings and standard components, tin aerosol cans: 1) do not inhibit sorting or reprocessing, and 2) are consistent with existing recycling infrastructure. Therefore, they meet SB 343 Requirement 3 for composition and design compliance.

California SB 343 represents a shift from theoretical recyclability to proven, system-based recyclability. To make valid recyclability claims, companies must ensure their packaging meets all three core pillars:

• Collection – Broad access across the California population
• Sorting & Reprocessing – Verified flow through recycling infrastructure
• Design Compatibility – Packaging that does not disrupt existing recycling systems

For materials such as metal packaging (e.g., tinplate and aluminum aerosol cans), the pathway to compliance is generally strong due to established collection and processing systems. However, compliance is not automatic — coatings, components, and overall design must still be evaluated carefully to ensure alignment with SB 343 requirements.

From an operational perspective, SB 343 requires companies to move upstream:

• Engage suppliers earlier
• Validate material data
• Integrate recyclability into packaging design decisions
• Substantiate all labeling claims with credible data

Evergreen Resources supports this process by working closely with customers to:

• Evaluate packaging against SB 343 criteria
• Provide technical insight into material selection and design compatibility
• Align sourcing with compliant and scalable recycling solutions

By combining regulatory understanding with practical packaging expertise, Evergreen helps ensure that recyclability claims are not only compliant but also supported by real-world performance within the recycling system.

This article incorporates and summarizes information from official resources published by the California Department of Resources Recycling and Recovery (CalRecycle). The original sources are listed below for reference:

1. SB 343 Material Characterization Study – Final Findings (2023/2024)
   • Prepared by Cascadia Consulting Group; published by CalRecycle
   • Publication Date: April 4, 2025
   • Document ID: DRRR-2025-1750
   • This blog references data and findings related to:
     • Recycling system performance
     • Material collection, sorting, and outflow (e.g., metal stream classification such as M10)
   • Source available via: https://calrecycle.ca.gov/wcs/recyclinglabels/
2. SB 343 Frequently Asked Questions (FAQ)
   • Published by CalRecycle
   • This blog references guidance on:
     • Definitions of “recyclable” under SB 343
     • Labeling requirements and claim limitations
     • Interpretation of PRC §42355.51 criteria
   • Source available via: https://calrecycle.ca.gov/wcs/recyclinglabels/
3. SB 343 Recycling Labels Guidance Page
   • Published by CalRecycle
   • This page serves as the central resource for:
     • Regulatory updates
     • Supporting documentation
     • Implementation guidance
   • Source available via: https://calrecycle.ca.gov/wcs/recyclinglabels/