September 29, 2026 workshop: automatic transcript

Contemporaneous automatic capture of the CalEPA public webcast. Pacific Time timestamps. Recognition errors and interruptions are retained. This is not an official transcript.

CalRecycle Textile Stewardship (SB 707) Informal Regulatory Concepts Workshop - Full Transcript

Tuesday, September 29, 2026, 10:00 AM - ~2:36 PM PT (adjourned early)

Source: CalEPA live webcast (English), https://video.calepa.ca.gov/?event=5965127&video=1196763203

Transcribed from captured webcast audio (faster-whisper, automated - expect minor errors, especially names and jargon).

Timestamps are Pacific wall-clock.

AUDIO GAPS (not in this transcript):

- 10:00-10:05 (intro/housekeeping, ~5 min)

- ~10:18-10:48 (Topic 1 public-comment Q&A, ~30 min - recorder failure)

- 10:57:29-10:59:11 (~100 s)

- ~11:33-11:34 (~30-60 s)

- ~14:29:30-14:31:34 (~2 min)

- Lunch 12:00-13:00 had no spoken content (break).

---

chunk_100511 (starts ~10:05 PT)

[10:05:11] regulatory text and concepts related to responsible end markets, reuse and repair,

[10:05:18] convenient collection systems, and producer identification and exemptions. For Part 1,

[10:05:25] Alexander Edwards will discuss regulatory concepts related to responsible end markets, reuse and

[10:05:31] repair. In Part 2, Brett Johnson will discuss regulatory concepts related to convenient collection

[10:05:38] systems, and for Part 3, Rob Hammerstad will share regulatory concepts related to producer

[10:05:45] identification and exemptions. We also have some folks to help address questions. We have Emily,

[10:05:53] Emma and myself, and we have a whole fabulous team here to help coordinate.

[10:05:59] Next slide. We shared a discussion document via our listserv as well as posted on the public

[10:06:09] notice for today's workshop, the discussion document outlines the proposed regulatory concepts

[10:06:15] and language that we're going to discuss here today, and the type of feedback that cal recycles

[10:06:20] requesting. The QR code here on the screen will help you access that discussion document,

[10:06:27] and I'll give folks a moment to get out a device and scan the QR code if it's needed.

[10:06:48] All right, it looks like most folks are putting down their devices and accessing the discussion

[10:06:53] document, so let's kick it off to the next slide. As usual, there's going to be opportunities

[10:07:00] throughout the presentations to ask questions and provide your feedback regarding the concepts that

[10:07:05] we're presenting. We're going to pause after each and every topic for your comments and questions

[10:07:11] before moving on to the next topic, and we also have an opportunity at the end for any remaining

[10:07:17] input. If you're here in person, we have two microphones on both sides of the room.

[10:07:24] If you want to make a comment, you just go ahead and head over to those microphones,

[10:07:32] and we're going to alternate between in-person comments and Zoom comments. If you're joining us online

[10:07:39] and would like to make an oral comment on Zoom, please raise your hand and our folks over here

[10:07:45] will unmute you and let you know when it's your time to speak. As a reminder, if you're participating

[10:07:50] via webcast, you do not have an option to provide verbal comments, so go ahead and join the room or

[10:07:59] the Zoom if you would like to share your comments. We, of course, also encourage you to submit

[10:08:05] written feedback after the workshop. Our deadline is October 13th. We're accepting feedback

[10:08:13] through CalRecycle's public comment portal, as well as via email, to regulations at calrecycle.ca.gov,

[10:08:24] with the subject line September, 2026 textiles stewardship, informal regulatory concepts workshop.

[10:08:32] It's really helpful to get your feedback timely, and with that subject line, so our team

[10:08:38] make sure they know which workshop it's associated with. It's not the only subject that we work on

[10:08:44] here at CalRecycle, although it's very important. All right, now I'm going to turn it over to Alex

[10:08:51] to provide an overview of proposed concepts related to responsible end markets,

[10:08:57] reuse and repair. Alex. Thank you, Ali. It's nice to see familiar faces and new ones as well.

[10:09:04] As a reminder, I'm Alexander Edwards. I'm an environmental scientist in the textile EPR unit,

[10:09:09] and I'll be going through the first part of today's workshop, which has already been stated, but

[10:09:15] double emphasis, responsible end markets, reuse and repair. We'll go ahead and move to the next

[10:09:20] slide, please. So this slide provides an overview of the four major topics we'll be covering in

[10:09:27] part one of today's workshop. Those are criteria for responsible end markets, intermediate supply

[10:09:33] chain entities, ultimate disposition, reuse and repair. Now each topic built on statutory

[10:09:40] requirements in the Responsible Textile Recovery Act, and helps clarify how materials will move

[10:09:45] through the system from collection to final disposition. For each topic, we will share

[10:09:50] statutory background, along with the regulatory concepts under evaluation, and then open the floor

[10:09:56] to your feedback. Next slide. To begin, criteria for responsible end markets, the Act defines

[10:10:04] responsible end markets and requires that recycling and recovery practices benefit the environment

[10:10:09] and minimize risk to public and worker health and safety. The statute does not specify the criteria,

[10:10:15] documentation or verification steps needed to determine whether an entity qualifies as a responsible

[10:10:22] end market, or REM, or REM. It also does not clarify how REMs should be distinguished from other

[10:10:30] supply chain entities. Next slide. Here are the regulatory concepts. Cower cycle is evaluating

[10:10:39] for identifying and verifying responsible end markets. The goal is to establish a clear framework

[10:10:45] that helps PLOs and regulated entities determine which facilities qualify as responsible end markets

[10:10:52] under the statute. Cower cycle is considering whether regulation should create minimum expectations

[10:10:59] related to the following, and we will go into more depth and subsequent slides. For those topics

[10:11:05] are compliance with all applicable laws, demonstrated environmental benefits, minimizing risk to

[10:11:12] public health and worker health and safety, transparent tracking and reporting on materials,

[10:11:17] including chain of custody documentation, verification and auditing requirements, or audibility

[10:11:24] requirements, performance expectations such as recycle, laying yield rates, and roles across

[10:11:31] intermediate supply chain entities responsible end markets and ultimate disposition.

[10:11:38] Next slide. Cower cycle is evaluating whether regulations should specify the types of

[10:11:47] compliant standards that REMs must maintain and make available to PLOs or the department.

[10:11:54] The regulatory concept under consideration include requiring REMs to hold valid permits,

[10:12:01] licenses, and clearances for all operation involving covered products, conduct operations

[10:12:07] lawfully under all relevant local, national, and international laws, and be able to determine

[10:12:14] compliance upon requests by the PLO or Cower cycle. Next slide. The department is evaluating whether

[10:12:28] regulations should specify what benefiting the environment means for REMs handling covered

[10:12:34] products. A regulatory framework may require REMs to minimize emissions and affluent

[10:12:41] discharges from processes that handle covered products, reduced environmental contamination,

[10:12:47] including microfibers, microplastic, and PFAS-related release during processing,

[10:12:53] document compliance with environmental health and safety requirements in the PLO's plan and

[10:13:03] the annual report, and describe occupational mitigation efforts in the PLO's plan and annual

[10:13:09] report. Cower cycle is evaluating whether regulations should specify how REMs document and disclose

[10:13:21] information related to their operations. Under this concept, REMs may be required to maintain

[10:13:28] chain-acoustic records showing how covered products move through their facility for at least five

[10:13:33] years, document any complaints, violations, penalties, or enforcement actions upon them,

[10:13:40] maintain records of all permits, licenses, and clearances, provide records to the PLO upon

[10:13:46] requests, and disclose a type of covered products they accept and any incompatible materials they

[10:13:52] do not accept, and then lastly consent to the PLO audits. The department is also evaluating specific

[10:14:03] requests for feedback slides to help generate feedback and discussion on this item. If you are

[10:14:11] here in person and you'd like to make a comment, you can line up at the podium. If you're on Zoom,

[10:14:17] please go ahead and raise your hand, and we'll let you know when it's your time to speak and we'll

[10:14:21] unmute you. Let's transition over to the next slide so we can share the requests for feedback topics

[10:14:29] that we're looking for. All right, here's a variety of questions. We would love to hear your feedback

[10:14:40] and opinions on these. We'll give you a second to read through them, and give you a time to decide

[10:14:46] if you're going to raise your hand or walk up to the microphones. Do we have any comments in the room?

[10:15:00] Looks like you're up. And the microphone will likely be off. You can do a test test, and if not,

[10:15:08] then you know, you can press the button on the microphone. You have to hold it for a second,

[10:15:14] and then it'll turn green. It's green. Feel free to adjust. Yeah, we got you now. There you go.

[10:15:24] All right. Hi, everyone. Thanks for holding this workshop. I have prepared a few remarks.

[10:15:36] First of all, reuse is the cornerstone of textile circularity.

[10:15:41] Real quick, please state your name and affiliation so folks can associate you with your comment.

[10:15:47] Matthias Wallander. I'm the CEO of use again.

[10:15:52] And reuse makes textile circularity economically viable.

[10:15:59] And that depends on the ability to move material around the world between countries.

[10:16:11] This trade also sustains jobs, workplaces, and income all along the process.

[10:16:24] So I believe the concepts that are discussed here today must reflect how this reuse is.

chunk_104759 (starts ~10:47 PT)

[10:47:59] is to have them as balancing and put it out for reconciliation, so that's something that we also wanted to provide as feedback and share more comments on what we think is realistic in putting that into place.

[10:48:15] And lastly, our comment is on the reuse side.

[10:48:20] As someone else mentioned earlier, if we had the name of the commenter, but reuse is obviously everybody knows here sits at a higher raised raised management higher than recycling.

[10:48:34] And we do see that the bill has a lot of gates on managing recycling and making recycling to be more responsible.

[10:48:45] There hasn't been a lot of definitions around what responsible reuse or donation can look like.

[10:48:53] And we know that since pros responsibility is to direct more to reuse than recycle, we wanted to make some recommendation on what that responsible reuse can look like.

[10:49:09] And we know suggest some ways to vet the right markets for resale and donation, especially for the volume that is directed to the international markets.

[10:49:24] Thank you so much for those comments. We look forward to reviewing your comment letter with additional information on your specific recommendations. Appreciate you sharing today.

[10:49:41] Okay, Jessica Franken, you can now unmute yourself. Please restate your name and your affiliation and we'll take your comments and feedback.

[10:49:52] Thank you so much. And good morning. Again, my name is Jessica Franken and I am speaking today on behalf of smart, which is the secondary materials and recycled textiles association.

[10:50:05] I know you've heard from us several times, but for those who haven't.

[10:50:09] The members are basically the backbone of the critical infrastructure that is already delivering textile circularity and the outcomes of extended producer responsibility.

[10:50:21] Because our members are involved in the collecting, sorting, grading, repair, reuse, recycling and trade of use textiles both in the United States and internationally.

[10:50:34] I do appreciate the opportunity to provide input on all of the topics that were covered in the discussion document.

[10:50:42] It is a particularly detailed and consequential discussion document for smart members in particular.

[10:50:50] So we're still working through the language and considering how these different provisions interact with one another and consulting with our members.

[10:50:58] So the comments that I'll provide are going to be a little bit more high level, but we will be submitting very detailed comments by the comment deadline.

[10:51:09] With respect to the topic of reuse and responsible end markets, we really do appreciate how recycles efforts to clarify responsible end markets.

[10:51:21] In our initial assessment, we feel that some of the concepts outlined in the document appear to be more appropriate for recycling facilities, but their application to reuse is much more complicated.

[10:51:36] As you heard from Matthias Wallender early on, the reuse system that's currently in place and already delivering quite a bit of value from a circularity standpoint is highly decentralized international and often involves multiple stages of sorting, grading, wholesaling, distribution and resale.

[10:52:02] As you heard from Matthias domestic markets alone simply cannot handle the volume of reusable textiles that are collected in the United States, particularly after EPR is implemented.

[10:52:15] So international markets are really essential to keeping these usable products in circulation and out of disposal.

[10:52:23] These markets in these international destinations include many small and informal businesses and again cannot overstate the importance of the second hand clothing trade to these receiving economies.

[10:52:39] They provide access to affordable quality, a parable apparel that many in these countries would not otherwise be able to afford and support literally millions of jobs in these receiving economies and generate revenue for countless individuals who are part of the trade on the receiving end.

[10:53:03] So, you know, responsible end market requirements that are designed for domestic recycling facilities are not necessarily going to translate to this decentralized and international markets through which reusable textiles move.

[10:53:21] For reuse, we would suggest that cal recycle might consider a market or geographic level assessment.

[10:53:29] There are valuable markets outside of California and material is going to need to continue to move outside the state to manage the increased generation of material that needs to be managed through this important program.

[10:53:44] I will say that we did a lot of individual focus on what sort of criteria is needed to ensure that reuse is tracked and characterized and reported in an appropriate way separate from responsible end market recycling.

[10:54:05] So we have additional content coming up related to reuse and will value your comments there as well.

[10:54:13] Let's move to our next comment on zoom, please.

[10:54:16] Samantha Sabyrin, you can now unmute yourself and provide your comment feedback.

[10:54:23] Hi, thank you for the opportunity to speak today. My name is Samantha Sabyrin. I'm a staff attorney at just zero, a national nonprofit that advances zero waste policy.

[10:54:35] We are also a founding member of the Healthy Textiles Coalition, which is a diverse group of nonprofits, researchers, industry experts, manufacturers and farms working to advance nontoxic and decentralized regional textile systems.

[10:54:52] We appreciate caliber cycles leadership in moving SB 707 into its regulatory phase and for creating the space for public engagement at this important moment.

[10:55:01] I just speak to the transparency and performance expectation pieces of this, but we will also be it says accepts instead of just advertising that it can.

[10:55:13] Thank you for the opportunity to speak and we will also be submitting written comments.

[10:55:19] Thank you so much for your comments. These are some things that are on caliber cycles radar as well. We did identify in the discussion document that documentation of all complaints violations penalties and other forms of enforcement is is important for transparency.

[10:55:38] And if you have recommendations on specific performance expectations and how that should be verified, we would value your comments and your written letter.

[10:55:49] Next comment, please.

[10:55:52] Alexandra Ferra, please restate your name and your affiliation. You can now unmute yourself.

[10:55:58] Good morning and thank you to the caliber cycle staff for hosting this workshop. My name is Alexandra Ferra, and I represent Fibershed, a national nonprofit that develops regional and actual fiber systems that build soil and protect the health of our biosphere.

[10:56:16] We bring a ground level view of what genuine climate beneficial soil soil circularity looks like in practice and we're very excited to be here to help ensure that this program reflects the communities landscapes and living systems that California's fiber economy depends on.

[10:56:33] We hold an ex officio seat on the governing board of the PRO and are also a founding member of the Healthy Textiles Coalition that Samantha just introduced.

[10:56:42] Thank you so much for covering this important topic today. Since composting is a recognized and required end of life pathway under SB seven of seven.

[10:56:51] We believe that our REMs must reflect that Fibershed operates a natural fiber post industrial textile composting demonstration site at our learning center in point raise station where we've demonstrated that undied 100% natural fiber textiles.

[10:57:09] Safely and effectively break down into nutrient rich compost showing how soil the soil recovery is very possible and operational.

[10:57:18] However, not all textiles are compostable as was mentioned by the California composting coalition for composting facilities to function as.

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[10:59:11] like in practice and we're very excited to be here to help ensure that this program reflects

[10:59:16] the community's landscapes and living systems that California's fiber economy depends on.

[10:59:21] We hold an ex officio seat on the governing board of the PRO and are also a founding member

[10:59:26] of the Healthy Textiles Coalition that Samantha just introduced. Thank you so much for covering

[10:59:31] this important topic today. Since composting is a recognized and required end of life pathway

[10:59:37] under SB 7 of 7, we believe that our REMs must reflect that. Fiber shed operates a

[10:59:45] natural fiber post-industrial textile composting demonstration site at our learning center

[10:59:51] in Point Raya Station, where we've demonstrated that undied 100% natural fiber textiles

[10:59:57] safely and effectively break down into nutrient-rich compost, showing how soil recovery is

[11:00:03] very possible and operational. However, not all textiles are compostable, as was mentioned by

[11:00:11] the California Composing Coalition. For composting facilities to function as credible REMs,

[11:00:19] the designation criteria must include clear feedstock accepted standards that distinguish

[11:00:24] genuinely compostable natural fiber textiles from synthetic or blended or chemically

[11:00:29] treated materials that would contaminate finished compost. It would shed microplastics or

[11:00:36] introduce PFAS and other chemicals of concern into agricultural soils. So, we recommend

[11:00:43] CalRecycle to ensure that the REM designation framework developed under SB 7 of 7 and the

[11:00:49] composting infrastructure framework currently being developed under SB 1383 and SB 1046.

[11:00:57] For small and medium-sized compost facilities, our coordinated, we actually wrote a comment

[11:01:01] letter to SB 1046 just a couple weeks ago and can attach that to our comment letter we plan on

[11:01:07] sending for this workshop. Just to ensure that composting facilities of various sizes and capacities

[11:01:14] are designated as qualifying REMs and equipped with the standards and infrastructure

[11:01:21] necessary to receive natural fiber textiles safely and responsibly.

[11:01:25] Then, on performance expectations, the stated yield rates and material recovery targets

[11:01:33] in the discussion document alone, we believe favor high volume synthetic recycling and would

[11:01:40] systemically disadvantage lower volume but higher value natural fiber recovery pathways,

[11:01:46] including composting, performance criteria we believe should also include things like material

[11:01:53] quality outcomes, chemical contamination rates and market sustainability, and REM that processes

[11:02:01] large volumes into potentially toxic, low grade outputs or exports to offshore markets where

[11:02:08] tracking typically ends at the border should not necessarily outperform one that recovers

[11:02:13] smaller quantities and dissertified compost or high quality reclaimed fiber.

[11:02:19] So, we encourage cow recycle to help build a performance framework that values what happens

[11:02:24] to the material and subsequent communities, not just how much moves through the system.

[11:02:29] And we welcome the opportunity to continue these conversations with cow recycle staff

[11:02:34] and are happy to serve as a resource. So, thank you so much.

[11:02:39] Thank you so much for your comments. Really interesting. I'm really curious to better understand

[11:02:47] the amount of textiles that are going to composting operations currently and the potential

[11:02:53] for additional material through this program would really love your feedback on what you think

[11:03:01] are appropriate performance expectations related to yield rates and material recovery targets that

[11:03:07] would be more appropriate and appreciate you submitting a follow-up comment letter.

[11:03:13] Next comment please. Rachel Fulmer, you may unmute yourself. Please restate your name and your

[11:03:20] affiliation. Thank you. Hi, thank you. My name is Rachel Fulmer and I'm from the Natural Resources

[11:03:29] Defense Council. Thanks for putting on this workshop. My comments are very brief. I just want to

[11:03:34] second some of the things said by Serene from Gaia. I want to emphasize that cow recycle should

[11:03:41] ensure accurate accounting for recycled content claims in order to maintain truth and product

[11:03:47] labeling. This means the program should explicitly prohibit credit based mass balance accounting

[11:03:53] methods, which often result in deceptive claims about whether a product contains any actual

[11:03:59] recycled material on the rim framework. I agree with Gaia that facilities should be excluded

[11:04:06] from being granted rim status or maintaining rim status if they have a history of violations including

[11:04:13] violations of environmental permit requirements and worker safety requirements. And finally,

[11:04:19] there should be a clear public engagement pathway included as part of the rim assessment so that the

[11:04:25] public and impacted communities are able to engage on whether a facility can receive and maintain

[11:04:31] rim status. And that is it. Thank you so much. Wonderful. Thank you so much for those comments.

[11:04:42] Okay, Mert Topkou. Please restate your name and your affiliation and you can provide your comments.

[11:04:51] Thank you. Mark Topkou, co-founder and CT of Reass Factory, Berkeley, California.

[11:04:58] We are an enzymatic recycling company for PET and polyester,

[11:05:02] recovering the monomers from post-consumer material using enzymes and water.

[11:05:07] And we are building our first line in LA County. Two comments and maybe a question.

[11:05:12] Only sensible and markets. One is on the definition. My understanding is that the

[11:05:17] statues definition of recycling is written by function and excludes only burning and fuel.

[11:05:24] We really appreciate that approach and we ask the regulations to keep it that way and define

[11:05:29] the end markets by verifiable outcomes such as yields, hazardous waste, health protections,

[11:05:34] chain of custody and hold every pathway to those tests including ours.

[11:05:40] Second comment, maybe on the reporting,

[11:05:43] mechanical recycling, fiber to fiber and monomer recovery, take different feedstocks and complement

[11:05:50] each other, blended, dyed, finished polyester is where monomer recovery adds capacity to other

[11:05:58] pathways don't recover. If reporting and the needs assessment treat for all recycling as one

[11:06:04] category, we may potentially cannot see which capacity is missing. So we will ask that reporting

[11:06:11] potentially distinguish the pathways with reuse and repairable all of them.

[11:06:17] Maybe a question if a responsible end market can take polyester both from packaging and

[11:06:23] textiles like ours. Does the department plan to coordinate the textile and market criteria with

[11:06:29] the SB 54 rules already in place? Affiliation before providing comment. Thank you.

[11:06:37] Hi, this is Shira Lane with the atrium where creative innovation center for sustainability.

[11:06:43] Thank you so much for providing this opportunity to provide comments. I just wanted to put in

[11:06:49] just to take into consideration as you were doing this to think about a pathway for innovation and

[11:06:56] what I mean by that is we want to see a lot of really good responsible end markets and we really

[11:07:02] would like to see this innovation happening here in California. So as you're creating these regulations

[11:07:09] just to think about ways that new businesses can start producing and REMs and supporting

[11:07:18] the innovation process. And so yeah, that's all I wanted to say. I'm going to keep it brief. Thank

[11:07:25] you so much. Thank you so much, Shira. Hopefully you're engaging with LandBel USA on the needs assessment

[11:07:32] process because they're going to be looking at what sort of end markets exist now and what kind of

[11:07:38] expansions are needed to meet the requirements of the act. So definitely recommend engaging in that

[11:07:44] process and then of course that is going to continue through the plan development.

[11:07:49] Yes, I should have said thank you so much. I should have said I also am an advisor to LandBel,

[11:07:55] so thank you. Sure. Thank you, Shira. Next comment. Bianca Lopez, you can now unmute yourself.

[11:08:04] Please restate your name and your affiliation before providing comment. Thank you.

[11:08:12] Good morning. Can you hear me? Yes. Thank you. Good morning. My name is Bianca Lopez. I'm

[11:08:17] co-founder of a grassroots organization in the Central Valley and Stennis House County Valley

[11:08:23] Improvement Projects and we recently shut down our ways to energy incinerator and I want to make

[11:08:28] sure that we don't continue to allow any material to be burned in our communities and disadvantaged

[11:08:35] communities. And so as I'm listening to this conversation as a mom and as someone who works on

[11:08:42] environmental justice issues in my community, I keep coming back to some basic concerns about

[11:08:47] what we mean when we say responsible and markets. I understand why turning plastic bottles into

[11:08:53] clothing can be considered recycling, but personally I don't want to wear plastic and I don't

[11:08:58] necessarily want my children wearing plastic. I don't want my friends wearing plastic either.

[11:09:03] We're finding micro plastics in our water, our air, our soil and our bodies and that concerns me

[11:09:08] very much. When we talk about creating end markets for plastic by turning it into textiles, I think

[11:09:15] of the health contamination must be part of the conversation, not just whether we successfully

[11:09:22] diverted it from the landfill. I also worry about what else is in our clothing. There can be dyes,

[11:09:29] coating, treatment, plastic components and other chemicals and materials that consumers know

[11:09:35] very little about. If we're creating a system designed to keep textiles circulating longer through

[11:09:41] reuse and recycling, shouldn't we also be asking what are we keeping in circulation? I would really

[11:09:47] like to see more science and health information incorporated into what the PRO can consider a

[11:09:53] responsible end market. I also think consumers need better information. When I see a label that says

[11:09:58] made from recycled water bottles, it makes people think that this is environmentally responsible,

[11:10:05] but instead it's nasty, it's unhealthy. I want labels that help me understand what I'm actually

[11:10:12] wearing and the health effects. What's in this material? Does it shed microplastics? Are there

[11:10:20] chemicals of concern? What do we know about exposure? When will I get cancer? That's what I keep thinking

[11:10:30] about similar.

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[11:12:38] Similar concepts to propositions 65, not necessarily the same program, but the idea that people should have information so that we can make informed decisions for ourselves and our families.

[11:12:49] Thank you.

[11:12:55] Thank you so much for your comments, Bianca.

[11:12:59] Really appreciate you taking the time to share that with us.

[11:13:03] One point of clarification related to what the statute says.

[11:13:11] What it defines recycling or the term recycle to exclude certain technologies like combustion, incineration, energy generation, fuel production and other forms of disposal, but it doesn't explicitly ban those practices from occurring.

[11:13:30] Those will not count as recycling the period cannot report those as recycling, but the statute doesn't say that textiles can't be managed via disposal or other disposal like mechanisms.

[11:13:44] So there will be some material that's generated through the program that is contaminated or otherwise unable to be reused or recycled that will need to be disposed or managed via alternative management methods.

[11:13:59] Just by necessity.

[11:14:03] One other point.

[11:14:05] Oh, and then in terms of design.

[11:14:08] So really where I see the statute influencing design is through the system of eco-modulated fees that the PRO will be developing in their plan.

[11:14:19] It needs to take into consideration several things, including how the coordinate on that process.

[11:14:29] Thank you so much for for being here today, Carmel.

[11:14:31] Next comment, please.

[11:14:33] Welcome.

[11:14:34] Thank you.

[11:14:39] Hi, Serena and Rashad, please restate your name and affiliation and you can unmute yourself and provide your comment. Thank you.

[11:14:47] Thank you.

[11:14:48] I just wanted to add two brief comments to what I said earlier.

[11:14:52] I, Alexander Edwards asked us earlier if caricycle should clarify minimum expectations.

[11:15:00] And absolutely, we would really like to see not only minimum yields for facilities, but emission ceilings.

[11:15:09] And we would like these emissions to be calculated really from a whole life cycle perspective because for some recycling technologies.

[11:15:19] What creates, for example, the most greenhouse gas emissions thinking about solvolisis is not necessarily the stage of the use of the solvent in the facility, but the generation of the solvent upstream and then the disposal of the spent solvent at the end of life.

[11:15:36] Some early modeling has shown that switch, for example, to solvolisis could double greenhouse gas intensity from from from from the current from the current intensity.

[11:15:50] So this is not negligible and we really think cal recycle should should should if you know should clarify that with emission ceilings.

[11:15:59] And we do recognize that you know the ecosystem of recycling technologies is evolving and growing and it doesn't have to be a static ceiling, but it could be start and strengthen where every couple of years things are reassessed and and ambition can be raised.

[11:16:20] And just on a note on harmonizing with the packaging EPR that we've been following closely.

[11:16:27] So under that that EPR, the department did have the option to set criteria for responsible and markets in the regulation, but essentially it mostly opted to pass the buck to the PRO to set these in its plan.

[11:16:41] And specifically under SB 54, we really feel that the PRO is in an impossible situation of both having to comply with recycling targets and then having to set requirements for responsible and markets.

[11:16:55] And so naturally it has an incentive to stretch these requirements in order to achieve higher recycling rates, but in our eyes, it's really at the expense of the legal requirements for responsible and markets.

[11:17:10] And I just want to end on the notion of environmental benefit right environmental benefit, which is in the statutory definition of responsible and markets is a very powerful term.

[11:17:20] It's not just about reducing harm, it's about having an overall net positive effect.

[11:17:25] And we're fortunate in California, we have one of the leading scientists on a circularity, a doctor, a role at Gaier.

[11:17:33] And his work has shown that actually recycling always is a net cost to the environment, except when it displaces virgin production.

[11:17:44] And it only does so, it doesn't do so automatically as we'd like to think, it only does so when there are controls on overproduction.

[11:17:51] So when there are controls on overproduction and we are sure that a recycled textile is displacing a new textile and not creating just an additional feedstock on top of the overproduction, then we know that even though recycling always will have an impact as any industrial process will have,

[11:18:09] well, this impact is less than virgin production of the textile fiber, whether it's natural or synthetic, by the way.

[11:18:19] So for us, this really ties the whole reflection around recycling and responsible and markets back to the importance of design and tackling overproduction.

[11:18:30] Otherwise, we can't honor this requirement of environmental benefit and it'll only be watered down and then there may be legal issues that arise.

[11:18:38] And finally, I just want to echo Bianca Lopez's comments earlier from Valley Improvement Projects that we entirely support.

[11:18:47] Thank you so much.

[11:18:50] Thank you for adding those comments, Serene, appreciate that.

[11:18:54] I think we have a couple more on Zoom.

[11:18:57] Ivy Schlagel, please restate your name and your affiliation. You can now unmute yourself. Thank you.

[11:19:03] Great. Thanks so much. Hi everyone. My name is Ivy Schlagel. I'm from an NGO called Cannopy.

[11:19:10] We're global solutions focused in geo and we work with over 900 brand partners, mostly in the fashion sector to shift supply chains away from the use of wood fiber.

[11:19:19] We focus on scaling textile to textile recycling. So in addition to solving for textile waste, we generate this is a critical way to displace the use of wood fiber in the production of manmade cellulosic fibers or MMCF.

[11:19:32] MMCF is about 6% of the world's fiber production right now, but it's growing in demand as brand seeks substitutes, primarily to polyester, but also to cotton.

[11:19:42] So textile to textile recycling considered a critical solution for producing MMCF from cotton and poly textile waste, much of which cannot be transformed mechanically into another fiber.

[11:19:54] I mean, as has been mentioned here today, these technologies are quickly evolving and all of these ecomodulation schemes can evolve alongside of these and take into account evaluating the available technologies as they scale reach scale.

[11:20:09] The idea is to define how facilities fit into the supply chain between initial collection and the end markets where final processing or disposition occurs.

[11:20:24] The department is considering regulations that would clarify that any facility or operation excluding collectors and end markets receiving or processing collected materials other than the end market is an intermediate supply chain entity.

[11:20:38] Specifically, that facilities are considered intermediate entities, not end markets for any materials they send off site for further processing or disposal.

[11:20:49] It will also recognize that a single facility may serve dual roles. For example, an intermediate supply chain entity for materials that transfer elsewhere may be an end market or ultimate disposition for materials if fulfills it fully processes on site.

[11:21:07] Next slide. This slide provides a proposed definition for intermediate supply chain entity building on the regulatory concepts introduced in the previous slide under this proposed definition any facility or operation other than the end market that receives materials after collection is considered an intermediate supply chain entity.

[11:21:31] A facility owned by the collector is still considered an intermediate supply chain entity if it conducts processing or receives materials after processing has occurred.

[11:21:43] A facility is not considered an end market for covered products or materials from covered products it sends off site for additional processing or disposal even if it is an end market for other materials it fully processes on site.

[11:22:01] Next slide.

[11:22:02] All right, that one was pretty straightforward. So maybe only hour and 15 minutes for topics and feedback on this one.

[11:22:11] Do we have any folks in the room who want to share their feedback on intermediate supply chain entities?

[11:22:17] Hello all. Can you hear me okay?

[11:22:29] Yeah, we hear you fine. Thank you.

[11:22:30] All right, Alexia Bednarz with the Association of California Goodwills representing 13 regional independent goodwills that reside in California.

[11:22:40] So on the topic topic to intermediate supply chain entities we support a clear distinction between intermediate supply chain entities and entities responsible for ultimate disposition.

[11:22:51] The regulations should recognize that a facility is an intermediate supply chain entity when it sorts aggregates preprocesses or transfers materials to another facility for further processing or disposal.

[11:23:05] When the same facility fully processed the material into a usable product or a virgin substitute feed stock it should be treated as the responsible end market or ultimate disposition for that material stream.

[11:23:16] And then further just for more context to support accurate tracking the California Goodwill operators are able to comply with a standardized reporting framework that captures as applicable broad covered material categories such as textiles shoes linens we can provide more details on that later.

[11:23:39] And details on our part in the processing chain outbound weights and provide details on the next partner and the chain of custody for downstream destinations.

[11:23:49] It's also recommended that a data dictionary and reporting templates are provided to meet any requirements and consistent definitions will be essential for all the stakeholders so we can do comparable statewide reporting.

[11:24:03] Fabulous, we're really aligned. I think the proposed definition of intermediate supply chain entities the full intention is to distinct.

chunk_113403 (starts ~11:34 PT)

[11:34:03] These might be both.

[11:34:04] You might be an intermediate supply chain entity

[11:34:06] for some materials and a responsible end market

[11:34:08] for others, so appreciate your comments

[11:34:11] and look forward to your written.

[11:34:13] Anyone in the room before we go over to Elp?

[11:34:15] Ms. Wilson.

[11:34:21] Ms. Wilson, again, from New Echo Fab.

[11:34:25] I want to say number three for me.

[11:34:28] It felt like it should be net.

[11:34:29] You should be able to net weigh them dry.

[11:34:33] And then once they have been weighed, sorted,

[11:34:37] the question is reporting is necessarily

[11:34:38] pros is to demonstrate accountability

[11:34:40] for the ultimate disposition of covered products.

[11:34:43] And so if it comes in dry, it should be weighed,

[11:34:46] and then after it's been weighed,

[11:34:48] it should be sorted based on what kind of material it is.

[11:34:54] And then once it's been sorted and sent out,

[11:34:57] it should be a, you should have some kind of either

[11:34:59] a bill of lading or an invoice

[11:35:02] is saying that this went from this facility

[11:35:05] to that facility and they received it.

[11:35:08] And so for me, I strongly think that chain of custody

[11:35:12] is something that you can verify and go back and check.

[11:35:15] The problem, the only thing I could see for RN

[11:35:18] is that at the end, where they're in light,

[11:35:21] and I don't know where I can't,

[11:35:23] I can't speak when I don't have my sunglasses on.

[11:35:26] Sorry, for me, for what we do,

[11:35:30] once it gets to the end life.

[11:35:33] In Ghana, as some of you will probably know pretty well,

[11:35:38] Continental secondhand market receives approximately

[11:35:40] 15 million secondhand garments a week,

[11:35:43] but up to 40% of the used clothing bills

[11:35:46] are often unsealable and end up discarded

[11:35:49] in informal dump sites where they often end up burnt

[11:35:51] or littered into nearby rivers,

[11:35:53] beaches and into the ocean.

[11:35:55] And they're also used to fuel water heating

[11:35:59] at public bathhouses in an informal settlement

[11:36:02] nearby called Old Fadama, where pollutants are released,

[11:36:06] including benzene, polycyclic, aromatic hydrocarbons

[11:36:12] that make the local community sick.

[11:36:15] And Ghana's only one of several African countries

[11:36:17] on the front lines of the global textile waste trade

[11:36:20] with other countries, including Angola, Kenya,

[11:36:22] the RC Tunisia and Nigeria.

[11:36:25] For Latin America, our focus is on Chile.

[11:36:29] You may have heard of the Atacama Desert.

[11:36:32] Unfortunately, it is also the site of textile dumping,

[11:36:36] resulting in part from textile waste imports

[11:36:42] that are officially destined for reuse.

[11:36:45] And there we have a team of scientific researchers

[11:36:48] who've been tracking respiratory disease

[11:36:50] and infections and cancers.

[11:36:53] And they've noted a correlation

[11:36:55] with the increase in the size of the dump site

[11:36:56] that receives the textile waste from overseas.

[11:37:00] And so they're doing further research to see how much

[11:37:03] they can, whether they can establish causation

[11:37:08] of these exposures and these diseases

[11:37:11] and airborne microplastics are a focus of their research.

[11:37:15] So thank you for your efforts

[11:37:17] in improving traceability there so that we can support

[11:37:22] genuine reuse, but not support dumping overseas

[11:37:27] of US textile waste, thank you.

[11:37:31] Thank you for sharing information on those case studies

[11:37:34] and for your recommendations.

[11:37:37] Next comment, please.

[11:37:39] Hi, Kyrsten Buckland.

[11:37:41] You can now unmute yourself.

[11:37:42] Please reset your name and affiliation

[11:37:45] for the note takers, thank you.

[11:37:49] Hi, this is Kyrsten Buckland again

[11:37:51] with Kimball Sustainable Healthcare.

[11:37:53] Our healthcare textile pilot may be useful example

[11:37:56] for this distinction.

[11:37:58] The recycler receives aggregated healthcare textiles,

[11:38:01] sorts and deconstructs them and converts some of that material

[11:38:05] into recovered fiber.

[11:38:07] That fiber may then be sent to a spinner

[11:38:10] or manufacturer for incorporation into a new product.

[11:38:13] So in a pathway like that,

[11:38:15] would the recycler generally be considered

[11:38:17] an intermediate supply chain entity

[11:38:20] because the recovered fiber still moves off site

[11:38:22] for further processing with the spinner

[11:38:25] or manufacturer potentially representing the end market

[11:38:28] or could conversion into a usable recovered fiber itself

[11:38:32] qualifies the ultimate disposition

[11:38:34] depending on the output and market.

[11:38:36] Thank you.

[11:38:38] That's an excellent question

[11:38:39] and it's something that we're working through

[11:38:42] through the development of regulations

[11:38:44] where we're not able to provide feedback

[11:38:46] at this time on whether specific pathways do

[11:38:50] or do not meet the criteria to be considered a responsible end market

[11:38:55] and we would value your feedback

[11:38:57] on what you think is most appropriate.

[11:39:03] David Bender, please restate your name and affiliation.

[11:39:06] You can now unmute yourself before making comment.

[11:39:08] Thank you.

[11:39:14] David Bender, processor of waste

[11:39:17] into feed stocks and raw materials.

[11:39:22] Complete supporter of granular reporting surrounding

[11:39:27] all aspects of the intermediate supply chain.

[11:39:31] I just want to draw a cow recycles attention

[11:39:34] to this concept of weights.

[11:39:37] I think textiles may be in some cases

[11:39:40] little different than beverages

[11:39:43] and more similar to how the carpet and carpet

[11:39:46] PRO works for the processors.

[11:39:48] So I'm encouraging it to either be including weights

[11:39:54] but certainly weights on the output

[11:39:56] and how the carpet processors use mass balance

[11:40:01] to report every aspect of what they receive

[11:40:05] and what goes out the door.

[11:40:06] So what I'm really trying to say is a complete supporter

[11:40:09] of transparency in the reporting requirements.

[11:40:12] I'm just advocating that it can be the input weights

[11:40:17] or output weights because the devil is in the detail

[11:40:20] and it would be potentially extremely,

[11:40:24] it could be extreme extra costs

[11:40:25] that really aren't necessary

[11:40:28] if we're still achieving the goal

[11:40:30] and the transparency that everybody wants.

[11:40:34] Appreciate your recommendation, David.

[11:40:39] Any more comments on Zoom?

[11:40:40] Oh, love more.

[11:40:42] Jessica Franken, you can now unmute yourself.

[11:40:44] Please restate your name and affiliation.

[11:40:46] Thank you.

[11:40:49] Hi, Jessica Franken again with smart.

[11:40:52] I just wanted to respond to some of the comments

[11:40:55] that were made a couple of speakers ago.

[11:40:57] I think it was the Gaia representative

[11:41:00] regarding dumping of these materials

[11:41:04] in international markets.

[11:41:06] That representative had mentioned a 40% figure

[11:41:10] that 40% into the materials,

[11:41:13] leaving the Continental market are leaving as waste.

[11:41:16] And it should be noted that that's a figure

[11:41:20] that gets circulated and repeated over and over again,

[11:41:23] oftentimes by policymakers who are repeating

[11:41:26] media sources who are repeating policymakers, et cetera.

[11:41:30] But that particular study that she was referencing

[11:41:33] has never been published.

[11:41:36] I just would invite people who are interested

[11:41:38] in the topic of international textile waste trade,

[11:41:42] including as reuse to look at the work

[11:41:46] of the Basel action network,

[11:41:48] which was one of the pioneers

[11:41:49] behind the Basel convention itself since the 80s

[11:41:53] and who are tracking not only textile waste flows,

[11:41:56] but electronic waste flows, plastic waste flows,

[11:41:58] paper waste flows, they do tracking.

[11:42:01] And I...

chunk_115140 (starts ~11:51 PT)

[11:51:40] of their investigations as references in our submission. Thank you very much.

[11:51:44] Thank you for your follow-up, Serene. Do we have any more remaining comments on intermediate

[11:51:48] supply chain entities? We have nine minutes and I'm confident we can get through our next section

[11:51:55] with Alex's leadership. Let's do this. Perfect. So moving on to ultimate disposition,

[11:52:05] the statute places an emphasis on accountability for where covered products

[11:52:10] ultimately end up. And the PRO must be able to demonstrate how materials are managed across

[11:52:15] the system. While the law requires responsible handling of collected text cells,

[11:52:20] it does not define the different types of ultimate disposition or explain how they should be

[11:52:26] differentiated. And it is important to note that ultimate disposition is a term used in statute

[11:52:31] whereas intermediate supply chain entity was not. Next slide please. The department is considering

[11:52:40] whether regulation should define ultimate disposition as an overarching concept that encompasses

[11:52:46] all final destinations for covered products. Establish criteria for what qualifies as a final

[11:52:52] destination includes completion of conversion into useful products, feedstock, component materials,

[11:52:59] or any other true end point. It will clarify the distinction between ultimate disposition and

[11:53:07] intermediate supply chain entities as well as identify reporting requirements such as weights,

[11:53:12] conversion outcomes, and other metrics associated with each disposition pathway.

[11:53:18] It will also establish standards for clear transparent reporting across all types of ultimate

[11:53:24] dispositions. Next slide. That was it. See, I know we can do it. All right, comments on ultimate

[11:53:40] disposition in the room. Tell us what it is, he means. So Alexia Bednar is association to

[11:53:54] California Goodwill's. Generally, we support defining ultimate disposition as the final destination

[11:54:01] or completed conversion pathway for covered product and material after which there are no further

[11:54:07] material management step as reasonably expected within the relevant pathway. The definition should

[11:54:12] clearly distinguish direct reuse repair followed by reuse resale, recycling, conversion into a usable

[11:54:19] product or feedstock and disposal. California Goodwill's believes the direct reuse through a second

[11:54:28] hand market should be recognized as an ultimate disposition when the collected product is sold.

[11:54:33] There are also potential instances when unsold products can be utilized to serve as a community

[11:54:40] need often through community partners. And it's important to note that these unsold items can still

[11:54:45] be used within the products original intended use or downcycled just depending on the partner.

[11:54:53] To assist in meeting reporting obligations, California Goodwill's can provide either

[11:54:58] itemization of products recirculated into reuse through resale or wait depending on where the

[11:55:04] products are sold along the value chain. For those that don't know, we offer many different avenues

[11:55:10] to reuse and resell products so we give items multiple chances not to set our retail stores,

[11:55:16] but we have by the pound stores. So that's why it would vary between itemization and wait.

[11:55:25] So reporting should be designed to avoid double counting obviously and should allow reasonable

[11:55:29] estimation methods when the direct wing is not operationally feasible, provided the method is

[11:55:35] documented and then consistently applied. We also recommend a phase implementation of detailed

[11:55:41] ultimate disposition verification because the peer rows and participating entities should have

[11:55:46] time to establish systems, test their data quality and correct gaps before full enforcement of new

[11:55:51] reporting requirements. Great comments. The statute does require annual reporting on the total weight

[11:56:00] of covered products collected and their disposition broken down by fiber type categories. It sounds

[11:56:07] like that's consistent with how Goodwill currently gathers information. So you'll probably have

[11:56:13] more feedback when we get to the the reuse section. On Zoom. Oh, we've got people fighting in the

[11:56:20] room. Let's go to you first, Tony. I'm a little bit confused by the word ultimate here. What if a

[11:56:26] textile goes to Goodwill multiple times and it's cycle between multiple different hands of people

[11:56:31] is ultimate just like the death date of that fiber or can something have an ultimate disposition multiple

[11:56:36] times that it reaches multiple users? You are thinking about this in in in depth way. It is 1201 and

[11:56:45] folks are hungry. So let's take a break for lunch. We are going to resume promptly at 1 p.m.

[11:56:53] up. So please rejoin us back here or via Zoom or webcast and we'll get kicking off with

[11:57:01] additional content right at 1 p.m. Enjoy your lunch y'all.

[11:59:31] So on right now, I was like, I was like, I'm going to get rid of such a difference.

[11:59:49] I was like, I was like, I was like, I'm like, I'm going to get rid of such a difference.

[12:00:00] I'm going to get rid of such a difference.

chunk_121248 (starts ~12:12 PT)

chunk_123355 (starts ~12:33 PT)

[12:40:53] Disregard

chunk_125541 (starts ~12:55 PT)

[12:56:43] Operations standards, these repair businesses are expected to meet.

[12:56:48] Next slide.

[12:56:50] This slide introduces regulatory concepts the department is evaluating to clarify expectations for authorized repair businesses under the Act.

[12:57:01] Concepts under consideration may include establishing operational standards for authorized repair businesses, including repair practices, safety requirements, and quality controls.

[12:57:13] And requiring PROs to describe all applicable rules, conditions, and performance expectations for authorized repair businesses in their stewardship plan.

[12:57:23] It would also involve developing reporting requirements for repair businesses such as documentation of repair methods, types of repaired covered products, and evidence of compliance with health, safety, and environmental laws.

[12:57:38] Requiring authorized businesses repair businesses will also need to maintain record demonstrating resale of repair products and compliance with program requirements.

[12:57:48] And lastly, it would also include ensuring PROs verify repair business performance through audits, monitoring, and periodic reviews.

[12:58:03] The statute now identifies redesigning and repurposing as a type of repair, but it doesn't explain what kind of activities fall into this category.

[12:58:13] It also doesn't provide guidance on how to tell when an alteration is considered repair versus when it becomes recycling.

[12:58:22] Without clearer definitions, PROs may have difficulty determining whether a product remains a repaired covered item or has been recycled into a new product.

[12:58:32] Additional required regulatory clarification would help ensure consistent interpretation and reporting across the program.

[12:58:41] Next slide.

[12:58:44] This slide introduces regulatory concepts under evaluation to clarify the meaning of redesigning and repurposing without the context of repair or within the context of repair activities.

[12:58:57] Concepts under consideration may include clarifying that redesigning and repurposing refers to transforming collected covered products into new items or products regardless of whether they are prepared for use, meaning the resale of a collected covered product to a consumer for its original intended use with or without repair.

[12:59:19] It will also identify when a transformation results in repair versus when it meets the definition of recycling, especially when the original product is substantially altered or converted.

[12:59:32] And it will also distinguish redesigning and repurposing activities from reuse and recycling to support accurate PRO reporting and oversight.

[12:59:44] Next slide presents a proposed definition for redesigning and repurposing, building on the regulatory concepts introduced in the previous slide.

[12:59:53] Under this proposed definition, redesigning and repurposing refers to altering or reconfiguring a collected covered product in a way that changes its appearance, fit, durability, embellishment or style.

[13:00:07] But the product must retain its original intended use to meet the definition of repair.

[13:00:13] Next slide, and back to you, Allie.

[13:00:16] All right, that was a lot of content that was handled really quickly.

[13:00:23] Pardon me, we're going to start in the room for comments and questions related to reuse and repair.

[13:00:31] We have two requests for feedback slides on this topic. We've got the first one on the screen and we'll toggle to the second one.

[13:00:39] They're also available in the discussion document for reference as well.

[13:00:43] Do we have any comments in the room?

[13:00:46] Thank you so much. My name is Joanne brush. I'm assistant director of the California Product Stewardship Council, sponsors of SB 707.

[13:01:00] My comments today are specific to the definition of repair.

[13:01:03] We'll write a formal letter with more detail on some of the other topics, but this one's really important to us for a couple of reasons.

[13:01:11] One, we've seen an established APR programs that repair and source reduction are not actually prioritized in operations and budget.

[13:01:20] So having really clear definitions and really clear directions on how the PRO approach repair.

[13:01:26] I mean, I can't speak for St Vincent, St Vincent, Paul Goodwill, but for us repair, that's a very high touch activity, right?

[13:01:36] It's a high cost. And so for us, that's going to be very difficult for us to attempt any type of repair.

[13:01:44] So I was just wondering if there be any consideration into incentive specifically for repair.

chunk_131635 (starts ~13:16 PT)

[13:16:35] in the development of the needs assessment process.

[13:16:37] The needs assessment is required to look

[13:16:41] at existing funding sources related to market development,

[13:16:46] which is unrelated.

[13:16:47] I should have started at the second part.

[13:16:49] They're looking at financial incentives

[13:16:51] to help achieve the state's goals related to repair,

[13:16:55] reuse, recycling collections,

[13:16:57] sorting disassembly, et cetera.

[13:16:59] And so provide your feedback now to land

[13:17:02] on what sort of incentives are necessary related

[13:17:06] to repair that would help your organization

[13:17:10] continue those important activities.

[13:17:12] The statute does require the PRO

[13:17:15] to prioritize repair and reuse.

[13:17:20] We'll take you in the room

[13:17:22] and then we'll switch it over to Zoom.

[13:17:27] Alexia Bednar's Association of California Good Wells.

[13:17:31] So on the topic of resale,

[13:17:34] we support clarifying that resale

[13:17:36] as a commercial transaction through an established secondhand

[13:17:38] or reuse business,

[13:17:40] including nonprofit secondhand retailers.

[13:17:43] The definition should not rely exclusively

[13:17:45] on one form of business registration, though.

[13:17:47] And I know that wasn't implied,

[13:17:48] but we just want to make that an of note

[13:17:51] because it could exclude legitimate nonprofit, tribal,

[13:17:53] or otherwise authorized reuse organizations

[13:17:56] who lawfully perform under a different registration structure.

[13:18:01] Secondarily, under the topic of authorized repair business,

[13:18:06] we support a reasonable statewide expectation

[13:18:09] for authorized repair businesses,

[13:18:10] including repair practices, worker safety precautions,

[13:18:14] quality controls, record keeping, et cetera.

[13:18:17] But do you want to note that requirements should be scaled

[13:18:19] to the type and volume of repair work performed

[13:18:22] and should not prevent smaller businesses

[13:18:24] who are often leading in repair

[13:18:26] and community organizations from participating

[13:18:30] within the program.

[13:18:33] And then to piggyback off of comments already made

[13:18:36] redesigned and repurposing,

[13:18:38] we generally support this proposed concept.

[13:18:41] However, the terminology tying it

[13:18:42] to original intended use becomes a little bit problematic

[13:18:46] and could cause confusion.

[13:18:47] For instance, some examples have already been provided,

[13:18:50] but a jacket could be redesigned into a skirt,

[13:18:53] window curtains could become a garment,

[13:18:56] in both instances the original intended use

[13:18:58] is arguably modified,

[13:19:00] however, it's still a covered product.

[13:19:05] I have a follow-up question for you.

[13:19:07] You had mentioned that when it comes to registering businesses

[13:19:10] that not necessarily having California

[13:19:13] or the Secretary of California be the main one.

[13:19:15] What are some examples of registration

[13:19:18] or any other documentation businesses might use

[13:19:20] that allow them to be able to conduct business

[13:19:23] in the United States?

[13:19:25] Well, let me take it back to my network

[13:19:26] and get specifics for you

[13:19:28] so that I can speak on behalf of everyone.

[13:19:30] But certainly like if you were certified 501C3,

[13:19:34] you would have documentation proving that

[13:19:36] we could provide.

[13:19:39] Thank you.

[13:19:43] Just to help answer that question,

[13:19:46] a business license out of any city or county

[13:19:50] that you do business in provides you with a business license.

[13:19:53] And that's for profit companies.

[13:19:56] We know that's different for nonprofit.

[13:19:58] So don't squeeze out the small for profit businesses.

[13:20:03] They can't, they're not incorporated,

[13:20:05] but they are legally registered with the city

[13:20:08] or the county in which they do business then.

[13:20:10] Thanks for adding that, very helpful.

[13:20:12] It was certainly not our intention to unintentionally squeeze

[13:20:16] out the small businesses.

[13:20:19] Let's turn it over to Zoom.

[13:20:23] Sheer lane, you can now unmute yourself.

[13:20:26] Please restate your name and affiliation

[13:20:29] before providing comment.

[13:20:30] Thank you.

[13:20:32] Hi, Sheer lane with HVM916, Creative Innovation

[13:20:37] Center for Sustainability.

[13:20:38] I would like to strengthen Joanne's comments.

[13:20:42] On upcycling, I wish we could include the word upcycling

[13:20:45] because upcycling keeps materials almost

[13:20:47] in their original form, just using creativity

[13:20:50] to turn them into something more useful or beautiful

[13:20:53] without breaking them down completely.

[13:20:55] And where recycling, this is how we explain

[13:20:58] when we do our education and outreach is recycling normally

[13:21:01] means it goes to an industrial location

[13:21:04] to break down the items into a lot more smaller components.

[13:21:07] And then it makes goods which often

[13:21:10] is a lower material quality over time.

[13:21:15] So kind of like the difference between those

[13:21:17] and I understand the problems of using upcycling

[13:21:20] and downcycling.

[13:21:23] Count and what doesn't.

[13:21:24] If we got it wrong, please do provide your comments

[13:21:28] to help further refine the definition for that term.

[13:21:33] Thank you.

[13:21:34] Thank you.

[13:21:37] Kestrel Jenkins McGill, you can now unmute yourself.

[13:21:42] Please restate your name and your affiliation

[13:21:44] before providing the comment.

[13:21:45] Thank you.

[13:21:50] Hello.

[13:21:51] My name is Kestrel.

[13:21:52] Thank you so much for having this opportunity to speak.

[13:21:56] I'm the creator of the first global fashion

[13:21:58] and sustainability podcast called Conscious Chatter.

[13:22:01] And the co-founder of Fashion is Out Rages,

[13:22:03] which is a research and education consultancy

[13:22:05] based in California.

[13:22:07] With my co-founder, Gabrielle Miller,

[13:22:09] we've been engaging in research around repair,

[13:22:12] including cultivating the steep understanding

[13:22:15] of what the local and global design techniques that are out

[13:22:19] there that could be considered when approaching

[13:22:21] a textile based item from both a sort of proactive

[13:22:25] and reactive repair perspective.

[13:22:28] We've hosted design for compliance textile

[13:22:31] EPR in California workshops in collaboration

[13:22:34] with Dr. Joanne Brash of CPSC during LA climate week, SF climate

[13:22:38] week, and across university settings,

[13:22:41] including ASU phedom.

[13:22:43] And in these workshops, we bring together

[13:22:45] these various stakeholders to sort of improve

[13:22:47] a diversity of thought and build real pathways

[13:22:49] for circularity, while also deepening awareness

[13:22:53] and driving proactive participation in SB 707.

[13:22:57] We're really focused on generating feedback loops

[13:22:59] and really ensuring that qualitative insights

[13:23:01] and lived experiences are considered and centered.

[13:23:04] And so with that in mind,

[13:23:06] I'll share some of our comments and questions.

[13:23:09] On number one, within the program,

[13:23:11] we do not believe that dead stock materials should be considered

[13:23:14] as a part of repair or reuse in the program,

[13:23:17] but rather a part of eco-modulated fees

[13:23:20] considered as an aspect of finished goods.

[13:23:23] On question four, thinking of peer-to-peer opportunities

[13:23:28] and sites because they're important,

[13:23:30] established parts of the current infrastructure.

[13:23:34] So thinking of the posh marks and the deep ops

[13:23:37] and these different platforms now thread up

[13:23:39] has a peer-to-peer option.

[13:23:41] So some brands already use these platforms

[13:23:43] to sell their excess inventory.

[13:23:46] So a question we have is if brands use these platforms

[13:23:48] to sell their products directly to consumers,

[13:23:53] will brands get credit for that?

[13:23:57] Then on question seven, from the lens of reporting elements,

[13:24:01] we really recommend including the time and cost

[13:24:04] involved in repairing items.

[13:24:06] I don't know if it can be a per unit possibility

[13:24:10] as well as the techniques used in the repair process

[13:24:13] because this could both help understand

[13:24:16] which techniques are being utilized the most,

[13:24:18] how to further invest in infrastructure

[13:24:20] to support those techniques,

[13:24:22] as well as provide valuable insights on what areas

[13:24:25] to further lean into when it comes to education

[13:24:28] in fashion and design schools.

[13:24:32] On question eight, when considering whether something

[13:24:35] falls under repair versus reuse or recycle,

[13:24:39] we're curious about whether an established list

[13:24:43] of repair techniques could be helpful

[13:24:45] to have as a sort of guideline in determining this.

[13:24:49] Of course, this would need to be regularly updated

[13:24:51] as new design for repair techniques

[13:24:54] are always being developed and discovered.

[13:24:57] So this would need to be some sort of dynamic document.

[13:25:01] And then also just wanna build on Dr. Joanne Brasius

[13:25:03] earlier comment on original intended use

[13:25:07] which others have also commented on.

[13:25:09] From our perspective, we believe that initial garment type

[13:25:12] isn't necessarily clear as repair and repurposing

[13:25:16] is a creative act that often leads to a garment

[13:25:20] being transformed into a new or different type of product.

[13:25:22] For example, one of my daughter's favorite dresses

[13:25:25] was previously a women's skirt

[13:25:27] and was transformed through creative repair techniques.

[13:25:31] Thank you so much for the opportunity

[13:25:32] to share our feedback.

[13:25:34] Thank you, Chris, for all those some great comments.

[13:25:37] You give us a lot to think about.

[13:25:39] I don't have answers to all of your questions,

[13:25:42] but some great things to contemplate as we continue

[13:25:45] the development of regulations.

[13:25:47] One particularly interesting thing that you brought up

[13:25:51] was it sounds like unsolved

[13:25:56] produced textile and apparel materials

[13:26:00] and whether the resell of that could count as reuse.

[13:26:05] And I think we need to think about that

[13:26:07] when I was looking at the definition of reuse

[13:26:09] in the statute.

[13:26:11] I was interpreting resell of collected covered product

[13:26:15] to mean that the PRO collected it through its network

[13:26:19] of established collection sites

[13:26:21] and then it is resold to a consumer

[13:26:26] for its original intended use.

[13:26:27] If there's different ways to interpret that,

[13:26:30] please do provide your recommendations

[13:26:33] in your comment letter.

[13:26:35] Absolutely.

[13:26:36] Thank you.

[13:26:39] Next comment, please.

[13:26:43] GU Song, you can now unmute yourself.

[13:26:45] Please restate your name and your affiliation

[13:26:47] before providing feedback.

[13:26:48] Thank you.

[13:26:52] Thank you again for the opportunity to provide feedback.

[13:26:54] GU Song from SuperCircle.

[13:26:58] I wanted to comment on the reuse and the definition

[13:27:03] about the rise of reuse channel.

[13:27:04] We fully support that issue focus more on the transactions

[13:27:08] or like we sell activities between register,

[13:27:14] businesses, but there's part of the resell

[13:27:18] work that we support for our rent and retailers.

[13:27:22] We actually put a lot of effort

[13:27:24] in vetting those business on our website

[13:27:27] and I know there's several other brands

[13:27:29] that do the same thing.

[13:27:31] And I would hope that that distinction would not be excluded

[13:27:35] from the definition of resell

[13:27:37] as it's an effort to keep textiles out of landfills.

[13:27:42] That's really interesting.

[13:27:43] I have a follow up question on how that works.

[13:27:46] So it's facilitated through a license

chunk_133751 (starts ~13:37 PT)

[13:37:51] already loved product that is being sold

[13:37:53] from a previous consumer to a new consumer.

[13:37:56] Fascinating.

[13:38:01] We're gonna have to think about that.

[13:38:02] Yeah, I would really appreciate any feedback you have

[13:38:05] on how that might fit in.

[13:38:07] Great.

[13:38:08] I haven't heard of transactions like that.

[13:38:11] Oh, okay.

[13:38:12] I will write something up for you guys.

[13:38:13] Thank you so much.

[13:38:20] Tanita Gray, you can now unmute yourself,

[13:38:23] and please restate your name and affiliation

[13:38:26] before providing comment.

[13:38:33] Hi, thank you so much.

[13:38:34] My name is Tanita Gray, and I want to say thank you

[13:38:38] for Cal Recycle and the textile stewardship team,

[13:38:41] for this opportunity to speak to you guys

[13:38:44] on such a monumental discussion.

[13:38:46] I represent Shoei's LLC, and what we do,

[13:38:50] we are a footwear recycling and recovery,

[13:38:53] consulting and training firm.

[13:38:54] We design waste management frameworks

[13:38:56] for footwear brands, designers and manufacturers,

[13:39:00] and we work with the community,

[13:39:02] or sorry, community organizations

[13:39:05] and educational institutes,

[13:39:08] educating and outreaching on understanding

[13:39:10] the circularity of complex material

[13:39:13] through deconstruction, training,

[13:39:15] design for end of life,

[13:39:17] waste management and EPR compliance.

[13:39:20] Our program has been adapted

[13:39:21] by the American Chemical Society

[13:39:24] because we believe that the chemistry

[13:39:26] is like the core component to textile waste

[13:39:30] and recyclability or environmental reentry.

[13:39:35] So for what we've been doing right now

[13:39:38] is building a EPR engine.

[13:39:40] It's a tool where clients can input their material analysis

[13:39:44] for a skew.

[13:39:45] This means that they can input all their materials

[13:39:48] that they are using per skew

[13:39:50] that can be color and material,

[13:39:53] as well as their packaging materials.

[13:39:56] It tells you the material science

[13:39:57] behind the materials being used,

[13:39:59] EMS emissions in regards to global supply chains

[13:40:02] and procurement from multiple countries,

[13:40:04] like some people get shoe bags from India,

[13:40:07] but it's produced in China and shipped to LA for sale.

[13:40:11] It assigns the end of life destinations.

[13:40:15] Clients can view their tier or circularity

[13:40:18] like if it's an actual circular end of life destination

[13:40:23] or of its linear.

[13:40:25] It also identifies friction scoring.

[13:40:28] Chain of custody is there as well

[13:40:30] and we provide recommendations on how to achieve

[13:40:33] less impact across the skews.

[13:40:36] The engine generates a product journey code

[13:40:38] that is customer facing

[13:40:40] and it outlines materials that will reenter the environment.

[13:40:43] It's similar to what previous comment made from Mrs. Lopez.

[13:40:47] It creates an ingredient list

[13:40:49] and a process transparency

[13:40:51] so that the consumers and retail customers

[13:40:54] can make informed purchase decisions.

[13:40:56] Client facing, it simplifies regulatory fees.

[13:41:00] It gives insight to brands and manufacturers

[13:41:02] on designing for compliance from day one

[13:41:05] before any material gets ordered.

[13:41:07] And currently this is before wear

[13:41:11] because it's so complex of a product

[13:41:13] but we can re-customize it for any product

[13:41:16] from a power of a handbags, accessories, home goods

[13:41:20] and signage, which I know is a very less talked about topic

[13:41:26] but any complex material product can be put into our new tool.

[13:41:30] If you would like information about that,

[13:41:33] I'm going to put the email chat we are on beta stage.

[13:41:37] So thank you for that.

[13:41:40] My comments right now do address footwear

[13:41:42] because it is an expressively covered product

[13:41:45] under section 42984,

[13:41:49] second three A, however,

[13:41:52] unlike most single product textiles,

[13:41:55] a shoe is composite of uppers, midsole, outsoles,

[13:41:58] adhesives, coatings and closures

[13:42:01] that follow different recovery rules and streams.

[13:42:05] Shoes cover tin out of the 11 waste characteristics

[13:42:09] that the EPA recognizes.

[13:42:11] And so I believe it needs special attention.

[13:42:14] Several of the concepts in the discussion document

[13:42:17] that we're looking at today would work better for footwear

[13:42:20] if other and other accessories,

[13:42:23] like handbags, even luggage.

[13:42:25] We also don't discuss luggage,

[13:42:27] carry-alls, arrow and auto textiles.

[13:42:31] These are all.

[13:42:33] Thank you so much for those comments.

[13:42:35] You had some really interesting feedback

[13:42:37] and we're definitely going to need to spend some time

[13:42:40] reading your written comment letter.

[13:42:41] And a couple things that I was considering as you were talking,

[13:42:47] the one of the concepts that we're considering

[13:42:50] is that responsible end markets would have requirements

[13:42:55] to be audited by the PRO regularly.

[13:42:59] And I think some of that stuff,

[13:43:02] the important criteria for ensuring

[13:43:06] that they are operating responsibly might be auditing

[13:43:11] requirements and potentially things

[13:43:15] that would be like record keeping

[13:43:17] and maintaining documentation.

[13:43:20] And we'll have to consider what makes sense

[13:43:22] in terms of like annual reporting requirements

[13:43:26] and what gets transmitted to CalRecycle

[13:43:30] versus what information the PRO is privy to

[13:43:34] and collects and maintains as part of its own processes.

[13:43:39] You talked a lot about education outreach as well,

[13:43:43] which is an incredibly important component of EPR programs.

[13:43:47] And the PRO is going to be developing

[13:43:51] a comprehensive education outreach program in its plan

[13:43:54] and we will be talking about

[13:43:56] producer responsibility plan requirements

[13:43:58] at our November 12th workshop.

[13:44:01] So just a plug for an upcoming workshop

[13:44:03] where we'll dive into some of these concepts in more detail.

[13:44:08] Anyone else have any?

[13:44:11] No, okay, next comment, please.

[13:44:15] Okay, Mira Mewsank,

[13:44:19] you can now unmute yourself.

[13:44:21] Please restate your name and affiliation

[13:44:24] before providing comment.

[13:44:25] Thank you.

[13:44:29] Thank you.

[13:44:29] Hi, my name is Mira Mewsank.

[13:44:32] I am an interdisciplinary textile upcycling artist

[13:44:35] at the FFOM Studio based in the East Bay.

[13:44:38] And my practice is about

[13:44:44] reclaiming discarded cloths

[13:44:47] and post-consumer clothes

[13:44:48] from the San Francisco Bay Area community

[13:44:51] and transform them into one of a kind

[13:44:53] wearable textile arts.

[13:44:55] So my practice diverts over 100 pounds

[13:44:59] of waste from landfills annually

[13:45:02] through cross-disciplinary collaborations

[13:45:05] and also recirculations within my own community.

[13:45:09] I also have started re-thing the runway last year,

[13:45:14] which is a community-activated platforms.

[13:45:16] We are all volunteers that connects

[13:45:18] and amplifies advocates, designers, brands

[13:45:21] and customers to accelerate the shift

[13:45:24] towards circular and regenerative apparel

[13:45:27] through education, storytelling

[13:45:29] and grassroots initiatives.

[13:45:31] So I feel very, thank you so much by the way

[13:45:34] for having this discussion.

[13:45:37] I'm literally working,

[13:45:40] currently literally working on finishing

[13:45:42] my upcycled collection for Open Style Week next week.

[13:45:45] My laptop is on top of my sewing machine table

[13:45:48] and I just felt called to at least give

[13:45:51] a little bit of a verbal comment.

[13:45:54] Yes, a lot of upcyclers like myself,

[13:45:58] we are all sole proprietorship entities.

[13:46:02] We are very small and yet we are providing

[13:46:05] a lot of values to our community.

[13:46:08] I also want to share that as someone who does

[13:46:12] all of the text-out-it-purposing work myself,

[13:46:15] the original intended use is not part of the objective.

[13:46:19] So keeping it like the original intended use,

[13:46:22] it's already being hammered down.

[13:46:24] This point has already been hammered down

[13:46:26] by all of the other commenters before me

[13:46:28] and I'm just going to add another hit on that nail.

[13:46:32] So it's not part of the objective

[13:46:34] to have the original intended use intact.

[13:46:38] I also want to share that in upcycling,

[13:46:40] combining different materials like garment and textiles

[13:46:43] to create something new and some of it

[13:46:47] actually more akin to wearable arts.

[13:46:50] That is very common and a lot of these is also,

[13:46:54] the value is also mostly subjective

[13:46:57] and something redesigned can continue to be redesigned

[13:47:00] and repurposed over and over and over again.

[13:47:03] So I also agree with Seren that upcycling

[13:47:07] is a marketing term before that it was the IY fashion

[13:47:11] before upcycling becomes a word

[13:47:14] in the past like five years or so

[13:47:16] and I feel like it's going to confuse more people

[13:47:21] if it's added to regulatory terms.

[13:47:24] In reality, like what I know right now,

[13:47:28] the term upcycling is already blurred much

[13:47:31] with recycling for the general public.

[13:47:35] So whenever I said like, oh, I'm cycling something,

[13:47:37] oh, are you recycling?

[13:47:39] MUM convenience standards for statewide collection systems.

[13:47:42] The department is considering regulations

[13:47:44] that may allow the minimum convenience standard

[13:47:47] in counties with a population of 100,000 in under

[13:47:50] to be met through a combination of collection locations

[13:47:53] which may include temporary collection sites

[13:47:56] that collectively provide convenience comparable

[13:47:59] to the specified minimum number of permanent collection sites.

chunk_135904 (starts ~13:59 PT)

[13:59:04] convenience once a minimum permanent site requirements are achieved.

[13:59:09] Additionally the regulations may clarify that a collection bin may count as a

[13:59:14] permanent site if it is if it is operated by an authorized collector and

[13:59:19] meets minimum operational criteria.

[13:59:22] And ideally identify expectations for how PROs must respond when it does not

[13:59:27] meet convenience requirements within a county.

[13:59:30] The statute also requires PROs to include signage for collection sites in

[13:59:38] their plans but it doesn't specifically require collection sites to

[13:59:43] display certain signage. It also doesn't outline what information needs to

[13:59:47] appear on signage which leaves room for inconsistent or unclear messaging at

[13:59:52] collection locations. Without clear standards consumers may not receive reliable

[13:59:57] guidance on where to drop off items or how the collection site operates.

[14:00:03] The department is evaluating regulatory concepts to establish consistent

[14:00:07] signage requirements for collection sites that may require authorized

[14:00:11] collectors to display PRO provided signage at collection sites.

[14:00:16] Minimum required information on signage including the name of the service

[14:00:20] provider contact information hours of operation and instructions on how to

[14:00:25] use the site. Expectations that signage be prominently displayed and easily

[14:00:30] visible to anyone visiting the site.

[14:00:33] And requirements for proper placement to ensure signage is accessible and

[14:00:37] readable in different types of collection environments. Pass it back to Ali.

[14:00:45] All right. We will start with Zoom this time.

[14:00:50] Comments regarding convenience. And as a reminder, we did touch on

[14:00:54] convenience in our August workshop. So this is a carryover on some related.

[14:01:00] No, I'll just keep talking until someone wants to come up.

[14:01:06] All right, let's start over on the left.

[14:01:11] Hi, Janay D'Ambrosio with D'Ambrosio trading. I didn't want to leave you

[14:01:15] lonely. So I'm just going to reiterate some things that I said in the last

[14:01:20] meeting. And it's I don't really know if there's an answer or solution for

[14:01:24] this. But with a minimum that's required to have permanent collection sites.

[14:01:29] I do understand thrift stores if they are follow the correct hours and what

[14:01:34] not are considered permanent locations. But if it's a small area or a small

[14:01:38] city or town that doesn't have the requirements to be met, my question would

[14:01:44] be if the mail back or the other solutions to offer a pickup service or, you

[14:01:52] know, a drop off of whatever that looks like, will those be prohibited if

[14:01:55] the minimum is not met on those permanent locations. And I only bring that

[14:02:00] to your attention is for the convenience factor that if, you know, sometimes

[14:02:04] there's cities and many times they don't allow collection bins within their

[14:02:08] city. I don't know the legalities on that. And we could battle on that all day

[14:02:11] long. We've done it for years. So I don't know exactly what that solution is.

[14:02:15] But if the state has a PRO stating that this is what we have to do, and the

[14:02:19] cities are not cooperating, what is the plan or strategy on that? And I definitely

[14:02:25] don't expect an answer today for that. But that's something that I would take

[14:02:28] into consideration the same thing that they brought up earlier about, you know,

[14:02:31] being registered with the state of California as a business. A lot of the cities

[14:02:36] have different permits and you're working with waste or excuse me code

[14:02:42] enforcement. And there's so many different obligations that we have to fill

[14:02:45] us collection sites that sometimes it's almost impossible to work with the

[14:02:48] city. So I just wanted to reiterate that sometime that this looks good. It's a

[14:02:53] good foundation. But to keep those things in a consideration as far as

[14:02:57] implementing other services. I'll respond to a couple of your points.

[14:03:02] Mailback and other alternative collection mechanisms are always allowed. It is

[14:03:08] separate and distinct from the mandatory collection site requirements

[14:03:14] dictated in statute. It's more meant as a supplemental activity as opposed to

[14:03:19] in lieu of. The PRO is always required to establish the minimum number of

[14:03:27] permanent collection sites or per population increment. It not be considered

[14:03:31] permanent collection sites, we believe, as they become contamination points and a

[14:03:36] huge risk to the success of the entirety of the program. There should be mandatory

[14:03:43] staffing and intake training standards as well as a requirement for sites to

[14:03:48] have hazardous waste disposal capacity on site for textiles. That cannot enter

[14:03:54] recovery streams. And then on signage, minimum signage requirements, we believe

[14:03:59] should include multi-lingual content and clear material acceptance criteria.

[14:04:04] Just due to California's textile waste streams, including residents and

[14:04:08] visitors who speak dozens of languages. And then on temporary sites and

[14:04:13] mailback, these types of recovery methods should maintain the same intake

[14:04:19] staffing and training standards as permanent sites. Temporary collection can't

[14:04:25] be an un-staffed drop point due to contamination risk. For mailback

[14:04:30] programs in particular, they're extremely costly to operate and generate high

[14:04:36] contamination volumes because there's no intake process at the point of

[14:04:41] packaging. If mailback programs are permitted, packaging should be

[14:04:46] purchasable through an online interface or available at collection sites,

[14:04:51] alongside educational materials that can help reduce contamination. Then

[14:04:57] finally, whatever convenience framework calmer cycle adopts, we recommend

[14:05:01] requiring the PRO to capture and report the volume of textiles rejected from

[14:05:07] recovery pathways at each site, contaminated or rejected materials that

[14:05:12] disappear from the data make it impossible to evaluate whether the program is

[14:05:17] actually working and how it can continue to be improved. Those are just some of

[14:05:21] our suggestions that we'll put into our comment letter. Thank you so much.

[14:05:24] Thank you for your suggestions. Great comments. One thing I'd like to highlight

[14:05:30] is the statute does have education and outreach requirements related to

[14:05:35] producing materials in languages other than English. So take a look at those

[14:05:40] statutory requirements and see if you have recommendations for further

[14:05:43] specification and regulations. Next comment on Zoom. No comments on Zoom. Any

[14:05:51] further comments in the room? Go ahead, Tony. I'm a little bit confused about how

[14:05:59] mailback would meaningfully increase convenience. Can't anyone mail anything from

[14:06:04] anywhere? Or is it like you're assuming that a mailback option here includes

[14:06:09] like a site in county that they're mailing to? I would love your feedback on how

[14:06:15] it could count for convenience. Okay, yeah. So the statute allows mailback.

[14:06:20] Totally, but it's not for an author. I think it's, you know, it provides convenience to

[14:06:25] consumers. It is not a permanent collection. Right, right. Question seven, it

[14:06:29] should not count those didn't mean to answer our own question. Yeah. There is a

[14:06:35] definition in in statute for collection site at least. And so we're just trying

[14:06:44] to figure out how mailback might fit in. And if there is circumstances where it

[14:06:49] counts towards anything, whether it's reasonable geographic. But like we need to

[14:06:54] maximize it in every capacity. Got it. Thanks, Tony. Nothing online still? Anyone else

[14:07:00] in the room? All right, so we're going to do something a little different for

[14:07:05] our next section. And we do have robust discussion questions in the discussion

[14:07:11] document. What Rob's going to do is he's just going to go straight through this next

[14:07:16] section on producer identifications and exemptions. We're going to skip the

[14:07:20] individual comment period. And then we're going to accept questions on this entire

[14:07:24] part at the end to help save us a little time. So go Rob. Hi everybody. Can you

[14:07:36] hear me? All right. I'm Rob Hammerstad. I'm the supervisor for the Textiles

[14:07:41] Enforcement Unit. I'll be guiding us through part three of today's workshop. Part

[14:07:47] three will be an overview of proposed regulatory concepts related to producer

[14:07:50] identification, product exclusion, and lists. Next slide, please. As you can see

[14:07:57] on the slide displayed section one producer identification includes four

[14:08:01] topics. Identification and registration process in or into the state duty

[14:08:07] assumption and small seller exemption process. Next slide, please. Section two product

[14:08:15] exclusion includes the following topics, second hand covered product, personal

[14:08:19] protective equipment exclusion process, section three additional lists

[14:08:24] includes the following topics list types and process to add a list entry. For

[14:08:29] each topic, we will present the concept or concepts before opening the floor to

[14:08:33] questions feedback and comments at the end of this section. So excuse me, not

[14:08:37] after each topic after the section. Next slide, please.

[14:08:43] Statutory background related to producer identification is on the slide and

[14:08:47] the following two slides. This slide illustrates the approach taken by the act

[14:08:52] in determining who is a producer and thus there is slide 70. Thank you. Okay,

[14:08:56] we'll now move to section two focus on exclusion of covered products. Topics

[14:09:01] include second hand covered product and personal protective equipment exclusion

[14:09:05] process. Next slide, please. Statutory background related to the exclusion of a

[14:09:12] second hand covered product is provided on this slide.

chunk_142020 (starts ~14:20 PT)

[14:20:20] Okay, moving on.

[14:20:30] Topic two, personal protective equipment exclusion process.

[14:20:35] The statutory background related

[14:20:36] to the personal protective equipment exclusion process

[14:20:39] is provided on this slide.

[14:20:41] These provisions carve personal protective equipment

[14:20:44] and certain military clothing items

[14:20:46] out of the statutory definition of apparel.

[14:20:49] Next slide please.

[14:20:53] Kawasaki is considering regulations

[14:20:55] to specify a standardized process

[14:20:57] for requiring a PPE exclusion through the PRO.

[14:21:01] A proposed regulatory framework is displayed on the slide.

[14:21:10] Next slide please.

[14:21:11] Thank you.

[14:21:15] Okay, and then section three,

[14:21:17] removed right along.

[14:21:19] Section three focused on additional lists.

[14:21:22] Topics include list types

[14:21:24] and process to add a list entry.

[14:21:27] Next slide please.

[14:21:28] Statutory background related to the list types concept

[14:21:32] is provided on this slide.

[14:21:34] These provisions relate to the content

[14:21:36] of each proposed additional list.

[14:21:41] Next slide please.

[14:21:42] Kawasaki lists considering regulations

[14:21:44] to require the PRO to populate each list

[14:21:47] with data from registrations

[14:21:48] and publish each list on the PRO website.

[14:21:52] The currently proposed lists include a small seller list

[14:21:55] and a personal protective equipment list.

[14:21:58] Each list would identify the relevant brand or trademark

[14:22:01] and the specific exempt product when applicable.

[14:22:04] Next slide please.

[14:22:10] And section three topic two process

[14:22:12] to add a list entry.

[14:22:13] The statutory background is provided on this slide.

[14:22:18] These provisions are related to producer registration

[14:22:21] and PRO list requirements.

[14:22:27] Next.

[14:22:29] Kawasaki lists considering regulations

[14:22:31] to standardize the process

[14:22:32] and information requirements for adding to

[14:22:34] or removing from any lists.

[14:22:43] Okay.

[14:22:46] Did you want to take it for a question and comment that?

[14:22:53] All right, yeah.

[14:22:55] We saved a bunch of time doing it that way.

[14:22:57] That was fun.

[14:22:58] Now we have a 35 minutes for questions

[14:23:01] and comments on this section.

[14:23:03] Don't we have a request for feedback slide

[14:23:05] or is this like a specific one with questions?

[14:23:10] Yeah, yeah.

[14:23:11] Let's pause it here for a second

[14:23:13] and see if folks have questions

[14:23:16] or feedback on these specific questions

[14:23:20] and refer to the discussion document

[14:23:22] on the ones that we presented

[14:23:24] while Rob was covering the other topics.

[14:23:29] What do you have to say about producer identification

[14:23:32] and exemptions online?

[14:23:39] I'm glad we didn't stop throughout

[14:23:41] for questions and comments on the sections.

[14:23:46] Okay.

[14:23:47] Well, if no one has anything to say about that,

[14:23:49] maybe you're all tired.

[14:23:50] Let's go to the next slide

[14:23:52] and here's another catch all on anything

[14:23:56] that we talked about today.

[14:23:57] Anything we missed, anything,

[14:23:59] any questions that you have?

[14:24:01] You want to preview on what we're talking about

[14:24:04] at upcoming workshops?

[14:24:06] What else do you have to share with us today?

[14:24:10] Or something you didn't get to say when you're dying.

[14:24:12] Go ahead, thank you.

[14:24:18] Yes, well, under use again.

[14:24:19] I'd like to respond to a comment earlier

[14:24:22] about the need for collection bins to be attended

[14:24:28] in order to reduce contamination.

[14:24:32] And we have a lot of experience with this.

[14:24:34] We have been collecting using unattended collection bins

[14:24:39] for 27 years.

[14:24:41] Our experience in California is...

chunk_143134 (starts ~14:31 PT)

[14:31:34] provide assurances that we have high quality and safe textiles that can be reused and

[14:31:41] have a genuinely sustainable second life in their countries.

[14:31:46] Thank you so much.

[14:31:49] Thank you for sharing that comment, Serene.

[14:31:54] Before we move on to the next slide, I wanted to share if you do provide written feedback

[14:31:59] and you're sharing any information that's confidential speaking to what you were just

[14:32:05] talking about Ms. Wilson.

[14:32:06] Please do clearly mark any confidential records as such when you share it because otherwise

[14:32:12] any records submitted to Cal Recycle is subject to the Public Records Act and we do often

[14:32:19] get requests for to release comments that we receive through workshops.

[14:32:24] So just be aware if you do provide confidential information, mark it as such so we can treat

[14:32:29] it as such or at least evaluate it for potential reduction when we do get PRAs.

[14:32:38] Yeah, yeah, yeah, yeah, use the make.

[14:32:47] Not this one.

[14:32:50] I just wanted to encourage people not to provide confidential information because I don't

[14:32:53] know that in this context we can protect any confidential information.

[14:32:57] So please describe it if you want, but don't provide any sensitive information.

[14:33:04] You know, once we have the rights in place, we might be able to have a process to protect

[14:33:07] it.

[14:33:08] But I don't know that we have a process now.

[14:33:10] Sorry.

[14:33:11] Thank you, lawyer.

[14:33:12] That's.

[14:33:13] Don't give me any confidential records.

[14:33:18] I'm sorry, Travis, what?

[14:33:21] Oh, yeah, yeah, yeah.

[14:33:23] Okay.

[14:33:24] In case you didn't hear on online, what Jennifer was saying is if you want to provide confidential

[14:33:29] stuff, don't because we might have to release it.

[14:33:34] We have public records, act requests because we don't have a process in place, but schedule

[14:33:38] a meeting with us.

[14:33:39] Let's talk about it instead, right?

[14:33:41] All right.

[14:33:43] And then based on the information shared during this workshop, we may follow up with you

[14:33:48] directly.

[14:33:49] If we have questions or additional feedback on the content that you've shared, that's

[14:33:54] another reason why that sign up sheet in the back is so helpful.

[14:33:57] So we know who's in the room, who you represent, and so if you haven't filled it out, please

[14:34:03] sign your name before you leave today.

[14:34:06] Okay.

[14:34:07] Now last slide.

[14:34:08] So to stay updated on CalRecycle's activities related to the Responsible Textile Recovery

[14:34:14] Act, please subscribe to our listserv.

[14:34:16] You can visit CalRecycle's website.

[14:34:19] We updated regularly with all the key activities that we're engaging in related to the program.

[14:34:25] You can always email our team at textiles at calrecycle.ca.gov.

[14:34:31] We've got a whole squad of folks that monitor that email box that make sure you get a prompt

[14:34:36] response.

[14:34:37] And thank you so much for being here today and providing all of this helpful insight to

[14:34:43] help inform the development of the regulations for this really important program.

[14:34:48] Have a good rest of your day.

[14:34:49] Look at us staying on time.