No, a curbside program is not required. Jurisdictions are not required to provide any specified type of commercial collection program. Section 18837 of the draft regulations requires jurisdictions to provide education, outreach, and monitoring to affected businesses to inform them of the state requirement to recycle and to tell businesses how they can recycle in the jurisdiction.
Regarding informing and educating businesses about recycling opportunities in the jurisdiction, the types and combinations of commercial recycling programs vary by jurisdiction and can include curbside collection, drop-offs, and utilizing mixed waste processing. Additionally, businesses may choose to self-haul material to a drop-off or recycling center, back-haul recyclables to a distribution center, arrange for the pick-up of recyclables, etc.