When California passed SB 54, the state sent a clear message to industry: plastic packaging would no longer be regulated only by intent, but by proof.
SB 54, formally known as the Plastic Pollution Prevention and Packaging Producer Responsibility Act, requires producers to take responsibility for what happens to packaging after it is used. Not just whether it is recyclable in theory, but whether it is actually recovered, verified, and ultimately processed.
For many sectors, this is already proving difficult.
For agriculture, it is proving existential.
Agricultural packaging is essential. It protects food safety, supports cold-chain logistics, and enables large-scale distribution. At the same time, it is used across farms, packing facilities, and distribution centers that do not fit into traditional municipal recycling systems.
This is why, in January 2026, California’s Department of Resources Recycling and Recovery (CalRecycle) withdrew its initial SB 54 implementing regulations during Office of Administrative Law review and reopened rulemaking, with a renewed focus on food and agricultural packaging categories.
The policy direction has not changed. The execution challenge has become unavoidable.
The question is no longer what the law intends.
The question is how agriculture can comply without disrupting operations.
In this context, one U.S. agricultural operator made a decisive choice.
GemPack Berries, a major U.S. producer and distributor of strawberries and berries, operates at scale in California agriculture. Facing the reality of SB 54 enforcement, GemPack did not wait for industry bodies or regulators to define a solution.
Instead, GemPack made a commercial decision.
The company selected Reborn Materials Inc. as its execution partner and entered into a contractual relationship to deploy a system designed to manage recovery, verification, and end-of-life accountability for agricultural packaging under SB 54.
This decision is what makes the current development meaningful.
Without a large agricultural operator committing to real deployment, SB 54 discussions remain theoretical. With GemPack committing to execution, the problem shifts from policy debate to operational reality.
On January 22, 2026, GemPack publicly declared the Full Cycle Framework at LA BioSpace, a research facility affiliated with California State University, Los Angeles.
This was not a pilot announcement or a sustainability campaign.
The Full Cycle Framework is an operating system designed to manage packaging responsibility from use through final disposition in real agricultural conditions. Reborn Materials designed and integrated the system architecture, while GemPack serves as the operating anchor, deploying it across its agricultural workflows.
The system was built with a simple constraint: if it disrupts food safety, logistics, or cost structure, it fails.
That constraint is why the framework is already operating under contract.
Reborn Materials is not selling a single material innovation or product.
Its role is systemic.
Reborn functions as the system integrator and operator, responsible for ensuring that packaging flows are recoverable, verifiable, and conclusively managed in a way that satisfies Extended Producer Responsibility requirements.
In SB 54 terms, Reborn’s role is to prevent the “breaks” where responsibility traditionally disappears: between use and recovery, between recovery and verification, and between verification and final processing.
To do that, Reborn selected technologies based on execution performance, not novelty.
At the core of the system are two technology pillars originating in South Korea.
The first is enzymatic depolymerization based on research from Kyungpook National University, led by Professor Kyung Jin Kim. The PET-degrading enzyme, known as KUBU, was identified through large-scale profiling of PET depolymerases and peer-reviewed research published in Science (DOI: 10.1126/science.adp5637).
KUBU is not a company. It is the enzyme itself.
Industrial commercialization and deployment are led by ZYEN Biotech, which scales and engineers the enzyme for use in plastic streams that cannot be mechanically recycled. Within the Full Cycle Framework, enzymatic processing addresses materials that would otherwise exit the system without a compliant pathway.
The second Korean pillar is GGenTec, a waste-to-value company specializing in low-temperature conversion technologies. In real agricultural operations, residual plastic will always exist due to contamination and material complexity. GGenTec provides the final processing layer, converting non-recyclable residuals into energy and feedstock rather than landfill.
Together, these technologies ensure that no material stream is left unmanaged.
Execution without verification does not meet EPR standards.
Material-level verification within the framework is provided by QNA Technology S.A., a materials science company listed on the Warsaw Stock Exchange (WSE: QNA).
QNA’s quantum-dot authentication embeds invisible identifiers into packaging, enabling scientific confirmation of material identity and handling throughout recovery and end-of-life stages. This shifts compliance from self-reported claims to evidence-based accountability, a requirement regulators increasingly emphasize.
The fact that QNA is a publicly listed company adds an additional layer of disclosure discipline to the system.
The Full Cycle Framework is not positioned as a California-only solution.
California is the starting point because it is the hardest environment. SB 54 represents one of the most demanding producer responsibility regimes in the world, and agriculture is its most complex use case.
If a system can operate here, it can be adapted elsewhere.
The U.S. plastic packaging market exceeds $130 billion annually, with agricultural packaging representing a growing segment. As EPR frameworks expand state by state, the demand is shifting away from individual materials and toward systems that regulators and operators trust.
This is why the framework’s origin matters.
It did not begin with a pitch deck.
It began with a grower making a decision.
The significance of this development is not that advanced technologies exist.
It is that a major agricultural operator chose to deploy an execution system built to satisfy regulatory reality, and that system integrates global technologies selected for performance, verification, and closure.
GemPack’s decision created the conditions for this framework to exist.
Reborn Materials designed the system to make it scalable.
Korean university research and industrial technology power its core.
A publicly listed European company provides verification integrity.
That combination is what turns policy intent into operational compliance.
As SB 54 continues to reshape packaging responsibility in California and beyond, agriculture may no longer be the exception category. It may become the reference case.
GemPack Berries
A U.S. agricultural producer and distributor specializing in strawberries and berries, operating at scale across California.
Reborn Materials Inc.
A U.S.-based sustainability systems company serving as the integrator and operator of the Full Cycle Framework.
ZYEN Biotech
A South Korean company commercializing enzymatic depolymerization technologies originating from Kyungpook National University.
GGenTec
A South Korean waste-to-value technology company providing low-temperature conversion infrastructure for non-recyclable plastics.
QNA Technology S.A. (WSE: QNA)
A Poland publicly listed materials science company providing quantum-dot based material verification technology.
Jason Kang
Chief Operating Officer
Reborn Materials Inc.
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