Used Mattress Recovery and Recycling Plan – Mattress Recycling Council


SCH Number
Public Agency
California Department of Resources Recycling and Recovery
Document Title
Used Mattress Recovery and Recycling Plan – Mattress Recycling Council
Document Type
NOE - Notice of Exemption
Document Description
The Used Mattress Recovery and Recycling Act (Public Resources Code sections 42985-42994) requires a mattress recycling organization to submit a mattress recycling plan to CalRecycle for CalRecycle’s approval. The mattress recycling plan must be designed to establish a convenient and cost-effective program to reduce illegal dumping, increase recycling, and substantially reduce public agency costs for the end-of-life management of used mattresses. Mattress Recycling Council (MRC), a nonprofit mattress recycling organization established by mattress manufacturers, renovators, and retailers, designs and implements the mattress stewardship program described in its plan. Since 2015, MRC has collected and managed used mattresses in California by establishing public no-cost drop-off sites, funding the collection of illegally dumped mattresses, and coordinating with retailers to offer pickup of used mattresses when new mattresses are delivered to consumers. On January 9, 2023, MRC submitted to CalRecycle a new mattress recycling plan, titled Used Mattress Recovery and Recycling Plan. CalRecycle approved the plan on March 29, 2023.

Contact Information

Sophia O'Meara
Agency Name
Job Title
Environmental Scientist
Contact Types
Lead/Public Agency


Other Information

Notice of Exemption

Exempt Status
Type, Section or Code
CEQA Guidelines sections 15308, 15061(b)(3), 15378(a)
Reasons for Exemption
CalRecycle’s approval of stewardship plans is not a “project.” A “project” is an activity “which has a potential for resulting in either a direct physical change in the environment, or a reasonably foreseeable indirect physical change in the environment (14 CCR section 15378(a)). CalRecycle stewardship plan approvals have no direct effect on the environment and no reasonably foreseeable indirect impacts on the environment. There are no requirements in the stewardship plan from which any environmental impacts, direct or indirect, can be discerned. There are no standards or targets set in the stewardship plan on which to base an objective analysis of any potential impacts. To impute any general or specific environmental effects from the approval of stewardship plans would be entirely speculative, and CEQA does not require a lead agency to speculate as to potential impacts. Even if the approval of a stewardship plan could be considered a project, it would be categorically exempt pursuant to section 15308 of the CEQA guidelines, as the approval of the stewardship plan is to assure the maintenance, restoration, enhancement, or protection of the environment (see Public Resources Code section 42985). CalRecycle is one of the agencies specified in Public Resources Code section 21159.4 required to perform environmental analyses for the adoption of certain rules and regulations pursuant to Public Resources Code section 21159 and section 15187 of the CEQA guidelines. However, CalRecycle’s approval of the stewardship plan does not create any requirement for the installation of pollution control equipment, or a performance standard or treatment requirement. As such, no environmental analysis is required pursuant to Public Resources Code section 21159.


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