RIS0996Enacted

Provides extended producer responsibility for packaging and paper, recycling of beverage containers, and provides general provisions for oversight of single-stage producer organizations.

Jurisdiction:: Rhode Island
Type:: EPR
Last action:: Jun 30, 2025

Plastic PackagingPaper PackagingGlassMetals

Next steps for producers

No producer action is triggered yet — track this measure

Next deadline: Sep 1, 2026

Applies toFor items sold in or with packaging at a physical retail location: (A) the brand owner if the item includes a brand; (B) the person licensed to sell under the brand/trademark if no brand owner; (C) the person licensed…

Obligations under this law

·After July 1, 2027, packaging and paper product producers must be members of a packaging producer responsibility organization (packaging PRO)
·Register with the packaging PRO
·Implement requirements of the approved packaging producer program plan

Program page →

No designated program action is recorded for this measure yet — treat the above as the general obligation and verify against the source text.

HEALTH AND SAFETY -- THE STATEWIDE IMPLEMENTATION ANALYSIS FOR A BEVERAGE CONTAINER REDEMPTION, PACKAGING, AND RECYCLING PLAN - Provides extended producer responsibility for packaging and paper, recycling of beverage containers, and provides general provisions for oversight of single-stage producer organizations.

Covered Products

·Packaging (paper, plastic, glass, metal, multi-material) sold or supplied in Rhode Island
·Paper products (made primarily from wood pulp or other cellulosic fibers) sold or supplied in Rhode Island
·Covered beverage containers (glass bottles, rigid plastic bottles, metal cans with capacity between 40 ml and 1 gallon) sold or distributed in Rhode Island

Producer Obligations

·After July 1, 2027, packaging and paper product producers must be members of a packaging producer responsibility organization (packaging PRO)
·Register with the packaging PRO
·Implement requirements of the approved packaging producer program plan
·Pay producer fees to the packaging PRO
·Report to the packaging PRO (at a frequency determined by the PRO): total amount by unit and weight of each type of packaging material sold/offered/distributed in RI in the prior calendar year, and all other necessary information
·After July 1, 2026, beverage producers must be members of a recycling refund PRO registered in RI
·Register with the recycling refund PRO
·Implement requirements of the recycling refund program plan
·Pay producer fees to the recycling refund PRO
·Provide necessary information for covered beverage containers to the recycling refund PRO at a frequency determined by the PRO
·Register with the recycling refund PRO the barcode and Universal Product Code of all covered beverage containers introduced into RI
·After January 1, 2030, packaging and paper product producers may not introduce covered materials unless they have a written agreement with a packaging PRO to operate under an approved packaging producer program plan
·After January 1, 2032, producers may not sell covered materials in RI unless covered services are provided through an approved program plan and the materials are reusable, refillable, recyclable, or compostable
·After July 1, 2029, persons may not sell or distribute covered beverage containers of a producer not participating in the recycling refund PRO or not in compliance with this chapter

Exemptions

·De minimis producers: global gross revenues less than $2,000,000 (until January 1, 2030); adjusted for inflation by department beginning January 1, 2030
·Packaging for infant formula (as defined in 21 U.S.C. § 321(z))
·Packaging for medical food (as defined in 21 U.S.C. § 360ee(b)(3))
·Packaging for fortified oral nutritional supplements for persons with cancer, chronic kidney disease, diabetes, malnutrition, or failure to thrive
·Packaging for products regulated as drugs or medical devices by the FDA, including associated components and consumable medical equipment
·Packaging for medical equipment or products used in medical settings regulated by the FDA
·Drugs, biological products, parasiticides, medical devices, or in vitro diagnostics for animals regulated by FDA or USDA
·Packaging for products regulated by EPA under FIFRA (7 U.S.C. § 136 et seq.)
·Packaging used to contain liquefied petroleum gas designed to be refilled
·Paper products used for newspaper print publications (including supplements/enclosures) with content from primary sources related to news and current events
·Paper products used for magazine print publications with circulation less than 95,000 that primarily include content from primary sources related to news and current events
·Packaging for hazardous or flammable products regulated by 2012 OSHA Hazard Communication Standard (29 C.F.R. § 1910.1200) that prevent the packaging from being source reduced or made reusable, recyclable, or compostable
·Packaging collected and properly managed through a paint producer responsibility program approved under RI chapter 24.12 of title 23
·Exempt materials as determined by the department
·Covered materials distributed by one producer to another producer, subsequently used to contain a product distributed to a commercial/business entity for production of another product, and not introduced to any other person
·Government entities (excluded from definition of producer)
·Registered 501(c)(3) charitable organizations and 501(c)(4) social welfare organizations (excluded from definition of producer)
·Beverages excluded from coverage: drugs regulated under 21 U.S.C. Ch. 9 § 301 et seq.; 100% fluid milk; infant formula; meal replacement liquids
·Additives of high concern do not include materials regulated under RI chapter 18.13 of title 23 (toxic packaging reduction act)

Key Deadlines

Jul 1, 2026registration: Department begins accepting applications from packaging PROs

Oct 1, 2026registration: Department may approve a single packaging PRO

Jan 1, 2026registration: Department begins accepting applications from recycling refund PROs

Apr 1, 2026registration: Department may approve a single recycling refund PRO

Jul 1, 2026compliance: Beverage producers must be members of a recycling refund PRO

Jun 1, 2026other: Recycling refund advisory council initial meeting

Mar 1, 2026other: Department establishes and appoints initial membership of recycling refund advisory council

Aug 1, 2026fee_payment: Department provides written notice to recycling refund PRO of one-time registration fee amount

Sep 1, 2026fee_payment: Recycling refund PRO establishes initial beverage producer fee structure

Nov 1, 2026fee_payment: Recycling refund PRO submits one-time payment to department in lieu of registration fee

Jan 1, 2027other: Service providers seeking reimbursement must register with the department (annually thereafter)

Mar 1, 2027other: Department establishes and appoints initial membership of packaging program advisory council

May 1, 2027other: Department provides written notice of annual registration fee amount to packaging PRO (annually thereafter on May 1)

Jul 1, 2027fee_payment: Recycling refund PRO submits annual registration fee to department (annually thereafter on July 1)

Jun 1, 2027other: Packaging program advisory council convenes initial meeting

Jul 1, 2027compliance: Packaging and paper product producers must be members of a packaging PRO

Aug 1, 2027fee_payment: Department provides written notice of one-time registration fee amount to packaging PRO

Sep 1, 2027other: Packaging PRO establishes initial packaging producer fee structure

Sep 1, 2027other: Recycling refund PRO submits recycling refund program plan to department

Nov 1, 2027fee_payment: Packaging PRO submits one-time payment to department in lieu of registration fee

Jul 1, 2028fee_payment: Packaging PRO submits annual registration fee to department (annually thereafter on July 1)

Jun 1, 2028other: Packaging PRO completes initial needs assessment

Jul 1, 2028compliance: Recycling refund PRO implements approved recycling refund program plan (or within 6 months of plan approval, whichever is later)

Jan 1, 2029other: Coordination plan created by packaging PRO and recycling refund PRO (if separate organizations)

Jul 1, 2029compliance: Persons may not sell or distribute covered beverage containers of non-compliant producers

Jul 1, 2029compliance: Covered beverage containers must have refund value of $0.10

Jan 1, 2030other: Packaging PRO submits packaging producer program plan to department (every 5 years thereafter)

Jan 1, 2030compliance: Packaging and paper product producers may not introduce covered materials without written agreement with packaging PRO under approved plan

Jan 1, 2030compliance: De minimis threshold: less than $2,000,000 global gross revenues (adjusted for inflation by department beginning January 1, 2030)

Apr 1, 2030reporting: Material recovery facilities and drop-off facilities begin annual reporting to packaging PRO, recycling refund PRO, and department (annually thereafter)

Jan 1, 2031compliance: Recycling refund PRO must achieve annual redemption rate greater than 65% starting calendar year 2031

Jan 1, 2031compliance: Packaging PRO implements first packaging producer program plan (by January 1, 2031 or within 6 months of plan approval, whichever is later)

Jun 1, 2031reporting: Recycling refund PRO submits first annual report to department (annually thereafter on June 1)

Jan 1, 2032compliance: Producers may not sell covered materials in RI unless covered services are provided through approved plan and materials are reusable, refillable, recyclable, or compostable

Jun 1, 2032reporting: Packaging PRO submits first annual report to department (annually thereafter on June 1)

Oct 15, 2032reporting: Department submits first biennial report to governor and legislative committees on recycling refund program (every 2 years thereafter)

Jan 1, 2033compliance: Packaging program: collection rate >50% and recycling rate >40% starting calendar year 2033

Jan 1, 2034compliance: Recycling refund PRO must achieve annual redemption rate greater than 85% starting calendar year 2034

Oct 15, 2034reporting: Department submits first biennial report to governor and legislative committees on packaging program (every 2 years thereafter)

Jan 1, 2037compliance: Packaging program: collection rate >65% and recycling rate >55% starting calendar year 2037

Jan 1, 2041compliance: Packaging program: collection rate >75% and recycling rate >65% starting calendar year 2041

Producer Definition

For items sold in or with packaging at a physical retail location: (A) the brand owner if the item includes a brand; (B) the person licensed to sell under the brand/trademark if no brand owner; (C) the person licensed to manufacture and sell under another's brand if no licensee; (D) the importer of record if no US person; (E) the first distributor in/into RI if none of the above. For e-commerce: the same hierarchy applies for inner packaging; the shipper is the producer of shipping packaging. Franchisors with RI franchisees are producers. Government entities and registered 501(c)(3)/(c)(4) organizations are excluded.

Fee Structure

Eco Modulated: Packaging PRO: annual fee per member producer varying by total amount of covered materials introduced in prior year (per-unit basis such as per ton, per item, or other unit); reflects program costs per covered materials type net of commodity value plus allocated fixed costs; eco-modulated to incentivize reducing packaging amount, reducing paper used, reducing additives of high concern, increasing reuse, increasing postconsumer recycled content, and enhancing recyclability/compostability. De minimis producers (global gross revenues <$2M) are not charged. Recycling refund PRO: material-specific fee based on cost to manage material minus scrap value; modulated based on use of domestically sourced postconsumer recycled content, compliance with design for recyclability standards, use of labeling to encourage recycling, and design factors that inhibit recyclability. Flat fee structure offered for de minimis beverage producers.

Enforcement

Rhode Island Department of Environmental Management: Civil penalty up to $1,000 per violation per day for first violation by a producer or PRO; up to $10,000 per violation per day for second and subsequent violations in any calendar year. Fraudulent activity: penalty of twice the amount received from fraudulent activity or $500, whichever is greater. Continuing to sell/distribute covered beverage containers of a penalized producer (after 60-day written warning): twice the value of containers sold in violation or $500, whichever is greater (waived if distribution/sales discontinued within 30 days of penalty assessment). Department must provide written notification and offer information before assessing penalties; must issue at least one notice of violation by certified mail; may only impose penalty 60 days after written notification received. Additional enforcement actions: corrective action orders, orders for continued program implementation, revocation of plan approval, requirement to revise/resubmit plan, additional reporting requirements. Penalties deposited in recycling refund program account or packaging producer responsibility program account.

Preemption Notes

No explicit preemption provisions found in the bill. The bill creates new state law chapters and does not address federal preemption or preemption of local ordinances.

Compliance Dimensions

Collection / Recovery Targets50% all covered packaging materials (aggregate) by 2033 (Weight); 65% all covered packaging materials (aggregate) by 2037 (Weight); 75% all covered packaging materials (aggregate) by 2041 (Weight)

“(a) Packaging program collection and recycling performance targets. (1) The packaging producer responsibility organization is to achieve the following collection and recycling performance targets: (i) Starting with calendar year 2033, and annually thereafter: (A) A collection rate that is greater than fifty percent (50%); and (B) A recycling rate that is greater than forty percent (40%); (ii) Starting with calendar year 2037, and annually thereafter: (A) A collection rate that is greater than sixty-five percent (65%); and (B) A recycling rate that is greater than fifty-five percent (55%); (iii) Starting with calendar year 2041, and annually thereafter: (A) A collection rate that is greater than seventy-five percent (75%); and (B) A recycling rate that is greater than sixty-five percent (65%). ... (a) Redemption rate performance targets. The recycling refund producer responsibility organization shall achieve the following performance targets: (1) Starting with calendar year 2031, and each year thereafter, the annual redemption rate aggregated for all covered beverage containers shall be greater than sixty-five percent (65%). (2) Starting with calendar year 2034, and each year thereafter, the annual redemption rate aggregated for all covered beverage containers shall be greater than eight-five percent (85%).”

Recycled-Content Minimums50% plastic film bags for bag-drop redemption program

“(2) If the standard bags for the bag-drop program are made of plastic film, the recycling refund producer organization shall: (i) Ensure that the bags have a minimum of fifty percent (50%) postconsumer recycled content;”

Eco-ModulationModulated on: Reducing amount of packaging per individual covered material necessary to efficiently deliver a product, Reducing amount of paper used to manufacture individual paper products, Reducing additives of high concern, Increasing amount of covered materials managed in a reuse system (reused enough times to have lower environmental impacts than single-use alternatives), Increasing proportion of postconsumer recycled content in covered materials (considering technical limitations and net environmental impact)

“(iii) Create incentives to reduce environmental impacts, which may include: (A) Reducing the amount of: (I) Packaging per individual covered material that is necessary to efficiently deliver a product without damage or spoilage and without reducing its ability to be recycled; (II) Paper used to manufacture individual paper products; and (III) Additives of high concern; (B) Increasing: (I) The amount of covered materials managed in a reuse system that are reused the number of times needed to have lower environmental impacts than the single-use alternatives of those items; and (II) Increasing the proportion of postconsumer material in covered materials while considering technical limitations and net environmental impact of using more postconsumer material; and (C) Enhancing the recyclability or compostability of a covered material;”

Fees0.1 USD Flat — covered beverage containers - refund value per container beginning July 1, 2029; Unspecified — packaging PRO one-time registration fee - amount determined by department (due November 1, 2027); Unspecified — packaging PRO annual registration fee - amount determined by department (due July 1, 2028 and annually thereafter)

“(a) Applicable refund value. (1) Every covered beverage container sold or offered for sale in the state shall have a refund value of ten cents ($0.10) beginning July 1, 2029. ... (1) A packaging producer responsibility organization shall annually collect a fee from each member producer that shall: (i) Vary based on the total amount of covered materials each producer introduces in the prior year calculated on a per-unit basis, such as per ton, per item, or another unit of measurement;”

PenaltiesUp to 10000 USD per day

“(a) Enforcement authority. The department may administratively impose a civil penalty of up to one thousand dollars ($1,000) per violation per day on any producer who violates this chapter and up to ten thousand dollars ($10,000) per violation per day for the second and each subsequent violation. (b) The department may administratively impose a civil penalty of up to one thousand dollars ($1,000) per violation per day on any packaging producer responsibility organization or recycling refund producer responsibility organization that violates this chapter and up to ten thousand dollars ($10,000) per violation per day for the second and each subsequent violation in any calendar year.”

Bans & RestrictionsCovered materials introduced by producers without written agreement with packaging PRO under approved plan (Sales Ban), 2030; Covered materials that are not reusable, refillable, recyclable, or compostable (and for which covered services are not provided through approved plan) (Sales Ban), 2032; Covered beverage containers of producers not participating in recycling refund PRO or not in compliance (Sales Ban), 2029

“(a) Packaging producer restrictions. After January 1, 2030, no packaging and paper product producer may introduce covered materials, either separately or when used to package another product, unless the producer enters into a written agreement with a packaging producer responsibility organization to operate under an approved packaging producer program plan. (b) After January 1, 2032, no producer may sell in the State of Rhode Island covered materials unless covered services are provided for the covered materials through a program in a packaging producer program plan approved by the department and the covered materials are: (1) Reusable and capable of being managed through a reuse system that meets the reuse rate and return rate required under chapter; (2) Capable of refill and supported by a refill system; (3) Included on the recyclable covered materials list established under § 23-19.19-7; or (4) Included on the compostable covered material list established under § 23-19.19-7. ... Beverage container sales and distribution restrictions. After July 1, 2029, a person may not sell or distribute in or into the state a covered beverage container of a producer that is not participating in the recycling refund producer responsibility organization or that is not in compliance with the requirements of this chapter or rules adopted under this chapter.”

PRO StructureSingle Pro · needs-assessment required · Packaging producer responsibility organization, Recycling refund producer responsibility organization

“(a) Appointment of packaging producer responsibility organization. By July 1, 2026, the department shall accept applications from packaging producer responsibility organizations to represent packaging and paper product producers in fulfilling the requirements of this chapter. ... (c) By October 1, 2026, the department may approve, for a period not to exceed ten (10) years, a single packaging producer responsibility organization... ... Option for single producer responsibility organization. (1) The department may appoint the same organization to be the packaging producer responsibility organization and the recycling refund producer responsibility organization.”

LabelingDeposit Mark, Recyclability, Disposal Instructions, Other

“(9) How beverage containers will be marked or consumers otherwise made aware of the beverage containers eligible for the applicable refund value; ... (12) "Compostable material" means a covered material that: (i) Meets, and is labeled to reflect that it meets, the American Society for Testing and Materials Standard Specification for Labeling of Plastics Designed to be Aerobically Composted in Municipal or Industrial Facilities (D6400) or its successor; ... (4) The charge for the refund value of covered beverage containers shall be separately stated on a receipt, invoice, or similar billing document given to the consumer. ... (iii) Include instructions on the bag how the bag should be utilized and recycled through a drop-off program.”

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Full bill text

2025 -- S 0996 SUBSTITUTE A AS AMENDED ======== LC002805/SUB A ======== S T A T E O F R H O D E I S L A N D IN GENERAL ASSEMBLY JANUARY SESSION, A.D. 2025 ____________ A N A C T RELATING TO HEALTH AND SAFETY -- THE STATEWIDE IMPLEMENTATION ANALYSIS FOR A BEVERAGE CONTAINER REDEMPTION, PACKAGING, AND RECYCLING PLAN Introduced By: Senators McKenney, Tikoian, Britto, Lawson, Sosnowski, LaMountain, Murray, Gu, Vargas, and Urso Date Introduced: May 02, 2025 Referred To: Senate Environment & Agriculture It is enacted by the General Assembly as follows: SECTION 1. Title 23 of the General Laws entitled "HEALTH AND SAFETY" is hereby 1 amended by adding thereto the following chapter: 2 CHAPTER 19.19 3 THE STATEWIDE IMPLEMENTATION ANALYSIS FOR A BEVERAGE CONTAINER 4 REDEMPTION, PACKAGING, AND RECYCLING PLAN 5 23-19.19-1. Short title. 6 This chapter shall be known and may be cited as "The Statewide Implementation Analysis 7 for a Beverage Container Redemption, Packaging, and Recycling Plan". 8 23-19.19-2. Statewide implementation analysis for a beverage container redemption, 9 packaging, and recycling plan. 10 (a) The department of environmental management (DEM), in collaboration with the 11 department of administration ( DOA), and the Rhode Island resource recovery corporation 12 (RIRRC), shall commission a statewide needs assessment to determine the infrastructure, policy, 13 and programmatic requirements necessary to support a statewide redemption and recycling plan 14 including packaging materials, paper products, standard and miniature size beverage containers 15 including, but not limited to, aluminum and bimetal containers, glass containers, plastic containers, 16 and other priority materials as designated by the department. 17 (b) By October 29, 2025, the department shall procure an independent third -party 18 LC002805/SUB A - Page 2 of 5 consultant with relevant expertise to conduct the assessment, which shall include: 1 (1) A baseline solid waste and recycling analysis, which shall include an analysis of the 2 following: 3 (i) A characterization of the statewide solid waste stream by material type, quantity, source, 4 and disposal method; 5 (ii) A breakdown of recyclable and compostable materials by jurisdiction, type, collection 6 method, and end-market destination; 7 (iii) An analysis of materials that are currently not captured but are recyclable; and 8 (iv) Current costs and revenues associated with municipal solid waste, recycling, and 9 composting operations, including tipping fees and contract terms. 10 (2) An infrastructure and capacity evaluation, which shall include an evaluation of the 11 following: 12 (i) An analysis and inventory of existing collection, sorting, and processing infrastructure, 13 including materials recovery facilities (MRFs), composting operations, and transfer stations; 14 (ii) An assessment of processing capacity gaps and identification of capital investments 15 required to expand local and regional processing; 16 (iii) A review of reuse and refill systems, including reverse logistics and retail -based 17 programs; and 18 (iv) An e valuation of current contamination and litter rates, material flow logistics, and 19 gaps in access to curbside and drop-off collection services. 20 (3) An assessment of environmental geographic considerations, which shall include an 21 assessment of the following: 22 (i) A demographic and geographic analysis of waste service access and participation; 23 (ii) An evaluation of public outreach, education, and participation in reuse and recycling 24 programs; and 25 (iii) Recommendations to enhance job quality, health and safety for facility and collection 26 workers. 27 (4) Economic and market impacts, which shall include the following: 28 (i) Identification of lost economic value due to landfilling of recyclable materials; 29 (ii) Job estimates and business opportunities related to increase d material recovery, 30 recycling, and reuse; 31 (iii) Barriers and recommendations for developing local end -markets and supply chains 32 that utilize recovered and redeemed materials; and 33 (iv) A cost -benefit analysis of a redemption and comprehensive recycling pro gram 34 LC002805/SUB A - Page 3 of 5 framework for all impacted parties. 1 (5) A redemption and recycling plan design review, which shall include the following: 2 (i) An evaluation of successful redemption and recycling program designs in peer states; 3 (ii) Recommendations for a Rhode Island redemption fee; and 4 (iii) An analysis of environmental benefits, including greenhouse gas reductions, material 5 recovery targets, and reduced litter and marine debris. 6 (iv) Consideration of recommendations provided in the final report of the special joint 7 legislative bottle waste commission to study and provide recommendations to protect our 8 environment and natural resources from plastic waste. 9 (v) Consideration of the program proposed in H6207/S0996 as introduced in the general 10 assembly January session AD. 2025. 11 (6) Suggested performance targets and phasing recommendations, which shall include the 12 following: 13 (i) Diversion goals, timetables, and metrics for assessing success under low, moderate, and 14 high-impact implementation scenarios; 15 (ii) Recommendations for investment timelines, education campaigns, and dashboard 16 designs, and reporting protocols to ensure transparency and accountability; and 17 (iii) Recommendations for addressing specific items in the waste stream including, but not 18 limited to, miniature size beverage containers. 19 (iv) An analysis of the performance targets and implementation timelines proposed in 20 H6207/S0996 as introduced in the general assembly January session AD. 2025. 21 (c) The implementation analysis pursuant to this section shall be conducted with input from 22 municipalities, quasi-public agencies, and regional planning entities and shall include direct input 23 from industry stakeholders and impacted communities. 24 23-19.19-3. Rhode Island redemption and recycling advisory council. 25 (a) DEM shal l convene a Rhode Island redemption and recycling advisory council to 26 provide guidance, review preliminary findings, and make recommendations throughout the 27 assessment process. 28 (b) The advisory council shall include, but not be limited to: 29 (1) One represen tative from each of the five (5) counties of the State of Rhode Island, 30 including Bristol County, Kent County, Newport County, Providence County and Washington 31 County from the public works department or with waste management authority; 32 (2) One representative from a Rhode Island-based packaging or consumer goods producer; 33 (3) One representative from a materials recovery facility operating in Rhode Island; 34 LC002805/SUB A - Page 4 of 5 (4) One representative from a composting or organics processing facility; 1 (5) One representative from a Rhode Island reuse or refill systems operator; and 2 (6) One academic or scientific expert on waste systems, environmental health, or circular 3 economy. 4 23-19.19-4. Rhode Island redemption and recycling advisory report. 5 (a) The department shall, prior to the final report required by this section, hold at least one 6 public hearing to solicit input on the draft implementation analysis before its finalization. 7 (b) An interim status report shall be submitted to the governor, t he speaker of the house, 8 the senate president, and the chairs of the house and senate environment committees no later than 9 April 1, 2026. 10 (c) The final report, including findings and recommendations, shall be submitted to the 11 governor, the speaker of the house, the senate president, and the chairs of the house and senate 12 environment committees no later than December 1, 2026. 13 SECTION 2. This act shall take effect upon passage. 14 ======== LC002805/SUB A ======== LC002805/SUB A - Page 5 of 5 EXPLANATION BY THE LEGISLATIVE COUNCIL OF A N A C T RELATING TO HEALTH AND SAFETY -- THE STATEWIDE IMPLEMENTATION ANALYSIS FOR A BEVERAGE CONTAINER REDEMPTION, PACKAGING, AND RECYCLING PLAN *** This act would require the department of environmental management, in collaboration with 1 the department of administration, and the resource recovery corporation, to conduct a statewide 2 implementation analysis for a beverage container redemption, packaging, and recycling plan. 3 This act would take effect upon passage. 4 ======== LC002805/SUB A ========

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