Blog | Environmental General Counsel

Aug 6, 20242 min read

EPR Packaging Programs: Lead Time Needed to Evaluate Producer Status

Companies who may qualify as “producers” under the EPR packaging programs [1] adopted by California, Oregon, and Colorado should plan...

May 28, 20243 min read

Taking Stock of the EPR Packaging Laws: Minnesota's New Program

Introduction Minnesota just joined the roster of states with extended producer responsibility (“EPR”) packaging programs, and New York...

Apr 15, 20246 min read

EPR Packaging Laws: Oregon's Program Plan Provides Roadmap for Compliance and Producer Fees

On March 31, Circular Action Alliance (“CAA”), the Producer Responsibility Organization (“PRO”) for California, Colorado, and the only...

Feb 27, 20246 min read

Exempted Materials under California's EPR Packaging Law (SB 54)

Producers who may qualify for an exemption under California’s extended producer responsibility (“EPR”) packaging law (“SB 54” or the...

Jan 20, 20243 min read

SB 54 _ California Selects CAA as PRO and Other Updates

Within the last month, California has made significant strides toward its bid to create a circular economy for certain packaging and food...

Dec 12, 20234 min read

EPR Packaging Laws: Submission of the First Stewardship Plan

Since July 2021, when Maine passed the nation's first extended producer responsibility ("EPR") packaging law, four other states...

Oct 29, 20235 min read

SB 54 Gears Up: a New PRO, a Producer Working Group, and Draft Regulations

by Catherine W. Johnson The Circular Action Alliance (“CAA”), a 501(c)(3) non-profit, is expected to be selected as California’s new...

Sep 25, 20235 min read

Why Did the Most Favorable Venues for Prop 65 Plaintiffs Rule for the Defense in EHA v. Sream?

by Catherine W. Johnson Introduction Environmental Health Advocates v. Sream, Inc., (2022) 83 Cal.App.5th 721 (Sream), and three other...

Aug 6, 20234 min read

Five Things You Really Need to Know About SB-54 - California's EPR Law for Single Use Packaging

By Catherine W. Johnson It is probably fair to say that SB 54[1] – California’s extended producer responsibility (EPR) law[2] imposing...

Jul 17, 20235 min read

Evolving Standards for Due Diligence and Vapor Intrusion: Consider State Guidance and Policy

As regulation of vapor intrusion continues to evolve and escalate costs at contaminated sites, due diligence practices for vapor...

Jun 6, 20232 min read

Planning for Success: Launching and Implementing an ESG Program

There is a difference between launching an ESG program and launching a successful ESG program, according to three experts on a June 1,...

May 3, 20236 min read

SB 54: Who Must Comply with California's Plastics and Packaging Act? The Gummy Bear Question

California’s Plastic Pollution Prevention and Packaging Producer Responsibility Act (the “Act” or “SB 54”)[1] is a variation of the...

Mar 31, 20233 min read

When Must Businesses Join a PRO under California's Plastic & Packaging Law? (Updated 11/17/23)

By Catherine W. Johnson On March 29, 2023, the California Department of Resources Recycling and Recovery (CalRecycle) held a workshop[1]...

Mar 26, 20232 min read

CalRecycle Begins to Implement California's Plastic and Packaging Act

On February 28, 2023, the California Department of Resources Recycling and Recovery, known as CalRecycle, held an informational workshop...

Feb 24, 20232 min read

California Draft Vapor Intrusion Guidance Now Final

On February 23, 2023, California EPA (Cal EPA) finally released a “final draft” version of the much-awaited vapor intrusion guidance,...

Feb 19, 20231 min read

Materials Covered under California's Plastics Legislation

California’s SB 54, or the Plastic Producer Responsibility Act, represents a substantial expansion of the increasingly popular form of...

Sep 27, 20221 min read

New Decision Limits Scope of Prop 65

In a landmark decision, a California appellate court ruled that only "direct" exposures are subject to Proposition ("Prop") 65 warning...

Jun 7, 20223 min read

It's a Global World: Product Stewardship

For a variety of reasons (e.g., consumer/shareholder demands, laws regulating chemical use, potential liabilities, corporate...

Feb 1, 20225 min read

ESG Checklist -- A Prop 65 Compliance Program?

In California, the Proposition (“Prop”) 65[1] landscape continues to evolve – notices of violations (“NOVs”) issued for products that do...

Feb 8, 20213 min read

California's Prop 65 - Companies with Fewer than 10 Employees (Updated, March 6, 2023)

By Catherine W. Johnson Companies with fewer than ten employees are exempt from California’s Proposition 65 warning requirements but may...

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