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California Updates SB 54 EPR Packaging Regulations
By 2032, all packaging sold in the state of California must be 100% recyclable or compostable. Does your organization have plans in place to comply?
For producers, brand owners, and CPG companies, the window to prepare for California's SB 54 extended producer responsibility (EPR) packaging law is narrowing quickly, and the expectations are coming into focus.
On March 19, 2026, CalRecycle (the state agency responsible for overseeing the regulations) resubmitted the final draft of the Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54) regulations to the California Office of Administrative Law (OAL). That action triggered a 30-working-day review period, with a decision expected no later than May 1 and potentially sooner if OAL grants CalRecycle's request for early effectiveness. If approved, the regulations will take effect immediately.
That immediacy carries significant downstream implications. Once the regulations are finalized, obligated producers will have just 30 days to register with the Circular Action Alliance (CAA), the producer responsibility organization (PRO) overseeing EPR implementation, and submit their 2023 baseline supply data. Depending on OAL’s timing, that puts the reporting deadline sometime in May, or no later than June 1. Reports can be submitted via an online reporting portal.
At the same time, a second major deadline looms: May 31, 2026. By that date, producers must also submit 2025 packaging supply data and source reduction data, critical inputs that will shape future fee structures and compliance obligations.
Reporting is a yearly obligation. Producers must submit updated data showing the total amount of covered materials supplied versus the previous year. The figures also must include packaging reductions achieved through elimination, lightweighting, reusable/refillable formats, or substitutions with non-plastic alternatives.
According to CAA, more than 2,500 producers have already registered, and over 2,000 reports have been submitted, covering 95 material categories. However, hundreds of producers remain unreported, many waiting for regulatory certainty. That strategy carries risk. The reporting process is data-intensive, and latecomers may struggle to meet compressed timelines once the rules take effect.
Meanwhile, CAA is advancing in parallel. The PRO says it remains on track to submit its California Program Plan by June 15, 2026. That submission will initiate a 60-day public comment period, followed by a 60-day revision window before final delivery to CalRecycle. Producers should expect the plan to serve as the operational blueprint for how SB 54 requirements translate into fees, collection systems, and compliance mechanisms.
CAA is also preparing to release estimated fee rate ranges by May 1, giving producers an early signal for 2027 budgeting and financial planning.
The key takeaway: SB 54 is entering its execution phase. Regulatory approval will not mark the beginning of compliance; it will compress it. Producers that have already begun assembling data, aligning internal systems, and engaging with CAA are positioning themselves to respond effectively. Those that have not should act now.
SB 54 EPR Packaging Targets
The California EPR packaging law aims to reduce plastic packaging and food service ware in the state by 25% by 2032 (compared to a 2023 baseline); recycle 65% of single-use plastic packaging and food ware by 2032; and ensure that 100% of packaging and food ware is recyclable or compostable by 2032.
To fund the implementation costs and to shift the financial burden from consumers to producers, the EPR program will collect $5 billion ($500 million annually) from industry members (producers/CPG companies/plastic resin manufacturers) over 10 years (2027–2037).
In February 2026, CalRecycle published mutliple needs assessments reports on collection, recycling processes, end markets, reuse and refill systems, source reduction actions and investments, consumer education, and access. These reports will guide the PRO's budget and program plan and detail how California will meet the packaging and plastic pollution reduction goals of SB 54.
On December 31, 2025, CalRecycle published an updated Covered Material Categories List, including updated recyclability and compostability determinations for each covered material category (CMC); and a first-ever recycling rate determination for each CMC. The publication lists 95 categories of packaging materials and types (e.g., plastic, glass, metal, paper and fiber, ceramic, etc.), with 45 considered "recyclable" and 21 deemed "compostable."
In September 2025, CalRecycle published the Covered Material Categories Reporting Guidance. It contains definitions and concepts, including a glossary of terms for describing covered materials; a step-by-step flowchart to assist users in categorizing covered material into CMCs; and the full list of CMCs, including examples.
SB 54 requires a 25% source reduction in single-use plastic packaging and food service ware by 2032. The Source Reduction Baseline Report estimated the amount (i.e., total plastic components and total weight of plastic) of single-use plastic packaging sold, offered for sale, or distributed in the state in 2023.
According to the report, more than 2.9 million tons of plastic went into producing single-use plastic packaging and plastic food service ware. Collectively, these items consisted of 171.4 billion plastic components. Using these baseline figures, the PRO must reduce single-use plastics by approximately 725,000 tons and 43 billion components by 2032.
In September 2025, CalRecycle published the Source Reduction Reporting Guidance, which provides advice on how to estimate the amount of plastic covered material sold, offered for sale, or distributed in the state, including the number of plastic components and the weight of the plastic covered material.
To keep abreast of SB 54 developments, visit CalRecycle's website or sign up for email updates about the EPR packaging regulation.
SB 54 Law Background
Officially titled the Plastic Pollution Prevention and Packaging Producer Responsibility Act and enacted in June 2022, SB 54 creates an extended producer responsibility organization and program to compel producers (CPG companies and plastic resin manufacturers) to pay for improvements in package recycling and plastic pollution mitigation.
The regulation established timelines for the creation of the PRO, graduated recycling rates for plastics and other types of single-use packaging, reductions in single-use plastics through the elimination of plastic packaging or switching to reuse and refill systems, and a target for packaging to be either recyclable or compostable.
Exemptions
Exemptions to the EPR legislation include beverage containers subject to the California Beverage Container Recycling and Litter Reduction Act, medical products and prescription drugs, medical foods, fortified oral nutritional supplements for special dietary needs, infant formula, refillable/reusable products, and hazardous materials, among others as more specifically identified in the legislative text.
Companies (producers, wholesalers, and retailers of consumer packaged goods) with less than $1 million in annual gross sales in the state are exempt from most requirements, but they must still ensure that all covered materials they sell are recyclable or compostable by January 1, 2032.
Key Dates
- January 8, 2024: CalRecycle selects the Circular Action Alliance as the state's PRO for SB 54.
- January 1, 2025: Deadline for producers of expanded polystyrene food service ware to demonstrate 25% recycling rate to CalRecycle.
- September 5, 2025: Producer registration deadline.
- November 15, 2025: Initial producer reporting deadline.
- May 2026: Final producer reporting deadline.
- May 31, 2026: Producers submit 2025 packaging supply data and source reduction report.
- June 15, 2026: CAA/PRO submits program plan.
- Mid-2026: SB 54 Advisory Board reviews plan and offers written comments.
- On or before January 1, 2027: CalRecycle approves plan, EPR program begins.
- January 2027: 10% source reduction in plastic packaging (compared to 2023 baseline).
- March 1, 2027: PRO remits initial California plastic pollution mitigation fund fees.
- July 1, 2027: PRO remits first administrative fees to CalRecycle.
- 2027–2037: PRO will collect $500 million per year from CPG companies for a plastic pollution mitigation fund and is also authorized to collect up to $150 million from plastic resin manufacturers.
- 2032: 65% of single-use plastic packaging must be recyclable.
- 2032: 25% source reduction in plastic packaging and food service ware (compared to 2023 baseline).
- 2032: All packaging must be recyclable or compostable.
Your Sustainable Packaging Partner
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The information contained in this article is intended for general information purposes only and is based on information available as of the initial date of publication. No representation is made that the information or references are complete or remain current. This article is not a substitute for review of current applicable government regulations, industry standards, or other standards specific to your business and/or activities and should not be construed as legal advice or opinion. Readers with specific questions should refer to the applicable standards or consult with an attorney. It is the customer’s responsibility to determine whether its filled product is subject to any applicable government regulations and to ensure compliance with such regulations.