California’s Textile EPR Ambition Hinges on Infrastructure and Local Regulation

Your estimate that roughly 1,500 additional collection sites may be required to meet SB 707’s convenience thresholds is striking. In operational terms, what does scaling at that magnitude actually entail—and where do you anticipate the bottlenecks emerging first?
Mattias Wallander: Building 1,500 more collection sites means a coordinated push to secure siting approvals, establish property partnerships, secure permitting, define servicing routes, and improve handling capacity. It is not simply “adding bins”. It requires predictable rules for placement and maintenance, and logistics and processing capacity to handle the added volumes responsibly. We already know that while bins are the most effective collection method, bottlenecks due to inconsistent permitting and zoning constraints slow or block siting, and these will get worse as the system comes under further strain with the implementation of SB 707.

The study documents granular municipal constraints—permitting layers, zoning exclusions, parcel limits, setback rules, and servicing requirements. From an operator’s standpoint, are these regulatory frictions incidental irritants, or do they fundamentally determine whether a statewide EPR network can function?
Mattias Wallander: They are fundamental for textile EPR networks. SB 707 relies on convenient access. If local rules limit where collection bins can be placed, cap the number of sites, or make operations economically unworkable, the system cannot achieve the coverage needed for meaningful diversion. In our report, we view these constraints as structural barriers and discuss the potential we could achieve if they were addressed.

Surveyed large wholesalers indicated that easing regulatory barriers alone could unlock significant volume increases. If those constraints were harmonised or streamlined, what scale of additional capacity could an operator like USAgain realistically activate in the near term?
Mattias Wallander: The report provides evidence that removing regulatory barriers could unlock potential for more collection, in particular via bins. Large wholesaler respondents indicated potential increases ranging from 25% to triple their current volumes. Using the minimum reported figures, the report calculates at least 15.5 million pounds of additional annual collection capacity in California from those respondents alone. For an operator like USAgain, the near-term capacity that is realistic is the capacity currently blocked by siting uncertainty and inconsistent local requirements.

The report is clear that global end markets remain essential to maintaining circular flows, citing France’s continued export reliance and the Guatemala case study. Yet the politics of export markets remain contentious. How do you reconcile the operational necessity of global reuse markets with legitimate concerns around transparency, labour conditions and downstream waste management?
Mattias Wallander: Global reuse end markets are operationally essential to keeping textiles circulating at scale, sustaining collection to prevent landfiling or burning textiles, offering affordable clothing options to Global South citizens, and supporting local economies. The Guatemala evidence is one of many research sets that demonstrates why this trade is positive: it supports livelihoods across local resale ecosystems, expands access to affordable clothing, and results in low waste rates.

At the same time, we do need to treat exports as part of a shared-responsibility value chain, with transparent reporting on grades/destinations, enforceable labour standards, and verified partners. And where downstream waste does occur, EPR-style funding from producers should help finance local waste management and recycling capacity rather than leaving importing communities to absorb the costs alone.

SB 707 simultaneously encourages local sorting and grading capacity. Given California’s comparatively high labour and warehousing costs, what would need to change—financially or structurally—for in-state processing to scale without eroding economic viability?
Mattias Wallander: Higher wages, along with the cost and availability of warehousing in California, can be a real hurdle to scaling local sorting and grading. Our report identifies practical mechanisms that can make local processing more viable, including local government support such as subsidizing warehouse space where that cost is a barrier. Generally speaking, growing instate processing requires enough consistent feedstock (collection volume), reliable outlets for sorted material, and financing incentives aligned to the outcomes SB 707 seeks. While we want to grow sorting and grading in California, we also want to acknowledge the benefits of sorting and grading that happens in importing countries like Guatemala, where local sorting provides much-needed local employment opportunities and supports local industries.

The next two years of rulemaking will shape how “convenience” and “responsible end markets” are interpreted in practice. What definitions or standards are you most concerned could be misaligned with operational realities?
Mattias Wallander: A key risk is disrupting a value chain that already functions well, rather than investing more in the system that exists and that we know, through our work, to be scalable. End-market and tracking standards that allow legitimate reuse pathways to keep textiles in circulation already exist - what we want to see now is Californian authorities using these to scale up reuse. The report also flags contamination and system overload as real risks if volumes rise without adequate operational capacity.

Another risk is the limitation of keeping textiles in the US. We know there isn't enough demand for the clothes in the US: this makes end markets outside the country essential for EPR success. When recovery targets are set under EPR, they should acknowledge the operational realities of end destinations for textiles and the need for export.

If SB 707 is executed as intended, how do you expect the recovery landscape to look by the end of this decade—not just in diversion rates, but in how producers design products, how municipalities regulate infrastructure, and how consumers engage with reuse?
Mattias Wallander: The report models 10% and 24% diversion scenarios and ties them to job creation and greenhouse gas reductions. For these scenarios to be achieved over the next decade, we would expect to see a denser and more equitable collection network that meets convenience expectations, more sorting and grading capacity, so textiles are directed to their longest and most productive uses. It would also mean municipalities aligning local rules on where collection bins can be placed with statewide recovery goals rather than unintentionally constraining the infrastructure SB 707 needs. Over time, a functioning EPR system should also influence producers through incentives and requirements that favour more circular product outcomes and make it easier for consumers to participate consistently, as reuse and recovery become convenient and normal.