California AB-2253 Would Ban Mass Balance Recycled Content Claims: What Food Brands Need to Know

California is moving on a bill that would force every product sold in the state to back up its recycled content claim with actual physical recycled material — and ban the credit-based accounting that lets brands claim recycled content from chemical recyclers without any recycled molecules in the actual package.

AB-2253, introduced by Assembly Member Tasha Boerner on February 19, 2026, and amended in April, is currently sitting in the Assembly Committee on Natural Resources. If it passes in roughly its current form, it would be the first US state law to formally outlaw mass balance accounting for recycled content claims — and it would apply to all consumer products, not just plastic food containers. Food brands using rPET, recycled polyolefins from advanced recycling, or recycled-content paper need to read this one carefully.

What the Bill Actually Bans

The operative text is short and specific. AB-2253 says any recycled content claim must be based on the actual physical recycled content in the product, and explicitly prohibits three accounting methods:

Credit-based mass balance accounting — where a manufacturer mixes virgin and recycled feedstock at a chemical plant and allocates the “recycled credits” to a subset of output that may not contain any of the recycled molecules.
“Book-and-claim” accounting — where recycled content credits are sold separately from the physical material, similar to how renewable energy certificates work.
Free allocation — assigning recycled content to outputs without a verified physical basis.

The bill instead recognizes three calculation methods that are acceptable: a segregated model (physical separation throughout production), a controlled blending model (verified mixing with documented ratios), and a rolling average percentage applied to the actual output. All require documented physical traceability from waste stream to finished product.

Manufacturers and suppliers would need to maintain written records confirming the recycled content was diverted from solid waste (preconsumer or postconsumer) and that the claim conforms to the Federal Trade Commission’s Green Guides as of January 1, 2026. The bill also widens the scope from existing law, which only covered plastic food containers, to apply to all products with recycled content claims sold in California.

Why Mass Balance Exists — The Chemical Recycling Angle

To understand why the plastics industry is uneasy about this bill, you have to understand chemical recycling. Mechanical recycling — grinding up bottles into flakes, washing, melting, and re-pelletizing — produces visibly traceable recycled resin. You can point to a chemical batch and say “this rPET came from those bottles.”

Chemical (advanced) recycling is different. Mixed plastic waste is depolymerized back to monomer or further broken into pyrolysis oil, which then enters petrochemical crackers alongside fossil naphtha feedstock. The recycled molecules and the fossil molecules become chemically indistinguishable, then get split into different polymer grades for different customers. Mass balance accounting lets the plant operator say “we put 10% recycled feedstock in at the front, so 10% of our output is allocated as recycled” — and certify a portion of customers’ resin orders accordingly. ISCC PLUS, the dominant third-party certification, governs how this is audited.

From the chemical recyclers’ point of view, this is the only practical way to commercialize advanced recycling at scale, because true molecular segregation isn’t feasible in a refinery. From the consumer advocacy point of view — and AB-2253’s sponsors include the NRDC and Californians Against Waste — this means brands can put “made with recycled content” on a package that contains zero physically traceable recycled molecules. Renee Sharp at NRDC framed it bluntly: consumers “deserve accurate information, not misleading accounting.”

Why This Matters for Food Brands

The food and beverage sector is squarely in the affected zone. Three categories are most exposed:

Advanced-recycled polyolefin (rPE, rPP) for flexible packaging. ExxonMobil, Dow, LyondellBasell, SABIC, and Eastman have all built or scaled chemical recycling capacity over the past three years, and they sell recycled-attribution resin to flexible converters supplying snack bags, frozen food bags, cheese, and ready-meal pouches. Most of that recycled-content claim sits on mass balance certification. If AB-2253 passes, food brands selling those products into California would no longer be able to use those mass-balance credits to support a recycled content claim on the package.

rPET from chemical depolymerization. Mechanical rPET is mostly fine — bottle-to-bottle closed loop streams have verifiable physical traceability. But chemical rPET from glycolysis or hydrolysis facilities (Eastman’s Kingsport plant, for example) typically uses mass balance allocation. Brands using that resin specifically to hit SB 54 recycled content targets need to verify whether their resin qualifies under AB-2253’s definitions.

Bio-attributed or “ISCC-certified” plastic packaging. Anything labeled with ISCC PLUS attribution is mass balance by definition. Compostable and bio-based PE made through mass balance accounting at petrochemical facilities would also be in scope if marketed as “recycled” or with related claims.

The bill does not directly affect SB 54 recycled content compliance calculations — those are CalRecycle’s separate accounting framework. But it would block brands from marketing the recycled content on the package or in advertising if the chain of custody is mass balance only. Read alongside SB 54’s final regulations from May 1 and the EU’s evolving green claims rules, the direction is consistent: regulators want physical traceability, not accounting equivalence.

The Federal RMMA Wrinkle

There’s a federal counter-move worth watching. The Recycled Materials Attribution Act (RMMA), proposed at the federal level in late 2025, would essentially codify mass balance attribution as a recognized recycled content claim under federal law — directly opposite to what California is doing. Industry groups including the International Sleep Products Association (ISPA, named here because mattress materials sit in the same accounting framework), the American Chemistry Council, and the Plastics Industry Association support RMMA and oppose AB-2253. They argue that without mass balance, the economic case for advanced recycling collapses, and the US loses ground to Europe and Asia on plastic-to-plastic circularity.

If both AB-2253 and RMMA pass in their current forms, you’d have direct California-vs-federal conflict on a marketing claim. That’s exactly the kind of dispute that ends up in federal court on preemption grounds, and the timing of either bill’s passage matters. AB-2253’s current calendar puts it through committee through mid-2026, with a possible floor vote later in the session.

What Food Brands Should Do Before the Vote

Don’t wait for the final bill text. Whether or not AB-2253 passes as written, the trajectory of regulatory expectations is clear. Five actions to take in the next 60 days:

1. Inventory your recycled content claims. Walk through every product label, marketing page, sustainability report, and ESG disclosure that mentions recycled content for packaging sold in California. Note which claims are backed by mass balance certification (ISCC PLUS, RedCert, similar) versus physical segregation.

2. Ask suppliers for chain-of-custody documentation type. Specifically request whether the recycled resin in each grade is delivered via segregated, controlled blending, or mass balance/book-and-claim. Suppliers should be able to answer this within a few business days.

3. Separate compliance accounting from marketing claims. Even if you’re using mass balance resin to satisfy SB 54 or other recycled content mandates in CalRecycle filings, you may need to remove or modify on-package claims if AB-2253 passes. Plan the label revision now, not after the bill is signed.

4. Identify alternative segregated supply. Mechanical rPET from deposit return systems, closed-loop rPE from industrial waste streams, and physically segregated post-consumer recycled paper all qualify under the proposed bill’s standards. Get quotes and validate supply availability — segregated streams are more expensive and supply-constrained.

5. Review FTC Green Guides compliance. AB-2253 incorporates the FTC Green Guides as of January 1, 2026 by reference. If you haven’t updated your environmental claims procedures since 2023, do that now — the FTC itself signaled tighter enforcement on recycled and recyclable claims in 2025.

The Bigger Pattern

AB-2253 is one bill in one state, but it represents a clear regulatory direction: physical, verifiable, traceable. Accounting tricks that were tolerated during the early phase of corporate sustainability claims are now being closed off across multiple jurisdictions — EU greenwashing rules, FTC enforcement, state legislatures, and Codex food safety guidance all converging on the same expectation. Brands that build their packaging sustainability narrative on documented physical content rather than certified credits will spend less on legal review and label revisions across the next regulatory cycle.

If you need help auditing your recycled content claims, mapping supplier chain-of-custody documentation, or sourcing segregated recycled-content packaging materials for California, EU, and federal compliance, our team can help. Reach out at gqthpack.com.