A Commonsense Step Forward on Lubricants and Packaging

How AB 2245 reduces costs, clarifies system design, and strengthens California’s approach to material management 

The National Stewardship Action Council supports California’s AB 2245 as a commonsense step to reduce costs and improve efficiencies and increase convenience of how lubricants and their packaging are managed at end of life. 

• The bill establishes a producer-funded and operated collection and management system for lubricants and packaging, building California’s existing infrastructure to ensure a seamless transition and an affordable statewide program. 

• At its core, AB 2245 reflects a simple principle of EPR: responsibility for end of life (EOL) management should primarily be with the producer who makes the design and marketing decisions that determine EOL costs. 

Why This Matters 

California’s SB 54 for packaging included lubricant packaging which should not be comingled with food grade packaging and the lubricants industry are the only outlet for lubricant recycling. 

• Lubricants and their packaging require dedicated management system to prevent hazardous materials from contaminating food grade packaging streams 

• AB 2245 fills that gap ensuring these materials are managed through a system designed specifically for their characteristics, while recycling packaging into new appropriate products such as new oil and lubricant containers in closed loop systems. 

• The lubricant producers already run highly effective programs in Canada with recycling rate of 89% in 2024 which is higher than any other program in California.  They know how to run a program cost-effectively and are willing to do it. 

Watch NSAC’s April 14 Testimony in Support of SB 2245

https://www.youtube.com/watch?v=qdlQLdsZz4A

In testimony before the Assembly Committee on Natural Resources, NSAC Executive Director/CEO Heidi Sanborn emphasized: 

• Not every product requires a producer responsibility solution, but lubricants and their packaging do 

• Producer responsibility reduces system costs and improves outcomes 

• Existing infrastructure will be leveraged to create a more efficient, scalable program 

Sanborn also noted that AB 2245 resolves a key issue by clarifying how lubricants packaging is managed relative to SB 54, ensuring the right materials are handled in the right systems.

Why NSAC Supports AB 2245 

AB 2245 reflects the kind of policy NSAC works to advance: 

1. Cost-effective statewide systems that work in practice 

2. Responsibility aligned with product design and marketing decisions 

3. Clear separation of hazardous materials from food-grade recycling systems 

4. Putting more HHW products under EPR which was the first recommendation of the California Recycling Commission in 2021.