SB 1383 procurement requirements, tracked against your target

How the target works

The requirement has applied since January 1, 2022. Your target is a quantity of organic waste, but you satisfy it by procuring products made from recovered organic waste — so every purchase converts into target credit at a rate CalRecycle sets for that product type.

Jurisdictions can use any combination of eligible products, and can either use the products directly or give them away:

• Compost — applied in parks, medians, and municipal landscaping, or distributed to residents.
• Mulch — subject to the eligibility conditions CalRecycle sets for the feedstock and producer.
• Renewable natural gas — from anaerobic digestion, used for fuel, heating, or electricity.
• Electricity from biomass conversion — procured under the conditions the regulation specifies.

Recycled-content paper is a separate obligation

Jurisdictions routinely conflate the two, then find a gap at reporting time. Recovered organic waste product procurement and recycled-content paper procurement are distinct requirements with distinct records, and CalRecycle’s Implementation Record guidance lists them as separate categories.

Both need evidence. Neither is satisfied by the other.

Reference: 14 CCR § 18995.2

Why jurisdictions miss the target

Rarely because they did not buy anything. Far more often, the buying was real but the record was not: compost applied by the parks department, mulch bought on a public works purchase order, and a giveaway event run by the sustainability coordinator, with no single person holding the running total.

Procurement is unusually prone to this because the purchases are made by departments that do not think of themselves as part of the waste program. The parks crew ordering compost is not thinking about SB 1383, and nothing in the purchase order asks them to.

The result is a jurisdiction that may well have hit its target but cannot demonstrate it — which, for compliance purposes, is the same as missing it.

Keeping a running total that survives the year

Connect provides a procurement tracker so purchases are recorded against the target as they happen, by whoever made them, with the supporting documentation attached. The total is current in March, not reconstructed in July.

Because procurement records file into the Implementation Record as they are created, the same entries satisfy the recordkeeping requirement and feed the annual report. One entry, three obligations met.

Recent flexibility worth knowing about

The procurement landscape has moved. AB 2902 and AB 2346, both enacted in 2024, gave jurisdictions additional options and flexibility for meeting the recovered organic waste product procurement requirement, and CalRecycle has issued guidance on using them.

If your jurisdiction wrote its procurement approach in 2021 and has not revisited it, there may be routes to compliance now that did not exist then. That is worth a conversation before you buy another year of product under the old assumptions.