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The American Herbal Products Association (AHPA) distributes dietary supplement regulation and enforcement news as Legal Alerts. The information presented in Legal Alerts represents the views and opinions of the original authors of the content and does not necessarily represent the views or opinions of AHPA. Distribution of dietary supplement regulation and enforcement news as a Legal Alert does not constitute AHPA endorsement of the content or legal advice. Please direct any questions about Legal Alerts to communications@ahpa.org.

Registration for CA EPR law generally required by July 1


Producer onboarding meeting for Circular Action Alliance scheduled for May 16

July 1, 2024 is the deadline for companies subject to Extended Producer Responsibility (EPR) packaging laws in any of several states, including California, to register with the Circular Action Alliance (CAA). CAA is the Producer Responsibility Organization (PRO) selected to implement and oversee many aspects of California EPR law compliance. Generally speaking, manufacturers of dietary supplements sold in California with at least $1 million in gross in-state annual sales are producers under the state’s EPR law and must register with CAA unless they plan to submit an independent EPR compliance plan. Registration can be performed at https://circularactionalliance.org/registration. CAA is also the selected PRO for EPR programs in several other states, some of which exempt dietary supplements from EPR requirements. The CAA site contains other information regarding the administration of these state laws. 


Registration with CAA requires submission of the following information:


  • Identification of the states in which the company is an obligated producer based on its understanding of relevant EPR statutes.
  • The producer’s legal business name.
  • A primary contact email address and phone number.


Links and information on state EPR statutes and producer definitions are available at https://circularactionalliance.org/producer-resource-center#definitions.


CAA will host a producer onboarding call on Thursday, May 16, at 7 AM Pacific (10 AM Eastern) to perform a high level overview of their activities and interactions with EPR laws and bills, with an opportunity to answer industry questions. This event requires separate registration, at the following address:

https://circularactionalliance.org/events-feed/producer-onboard-session-mcpsw.

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