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California Releases Updates on SB 54 EPR Packaging Law
Single-use packaging for products sold in the state of California must be 100% recyclable or compostable by 2032. Are you prepared?
CPG companies marketing products with single-use and other plastic packaging in the state of California must take action to comply with the state's SB 54 extended producer responsibility (EPR) packaging law. Producers had to register with the Circular Action Alliance (CAA), the producer responsibility organization (PRO) overseeing EPR implementation, by September 5, 2025.
Another producer deadline (i.e., reporting of 2023 packaging supply data) is fast approaching. By November 15, 2025, producers must submit baseline data for covered packaging materials (by type, weight, and component) placed on the California market for the 2023 calendar year via an online reporting portal. This baseline sets the foundation for tracking progress and measuring future reductions.
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.
In short, producers establish their 2023 baseline, report annually, keep records, and demonstrate year-over-year reductions.
The California EPR packaging law aims to reduce single-use 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 single-use 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).
SB 54 EPR Packaging Updates
On December 31, 2024, California released two new reports—Updates to Covered Material Categories and Source Reduction Baseline Report—related to its EPR packaging law, which comes into force on or before January 1, 2027.
The Updates to Covered Material Categories lists 94 categories of packaging materials and types (e.g., plastic, glass, metal, paper and fiber, ceramic, etc.), with 45 considered "recyclable" and 11 deemed "compostable." In September 2025, CalRecycle added another category—Paper and Fiber/Multi-Material Laminate/Paperboard with a Plastic Coating/Lining—to the CMC list.
Also in September 2025, CalRecycle published the Covered Material Categories Reporting Guidance. It contains definitions and concepts, including a glossary of terms for describing covered material; 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.
In March 2025, Governor Gavin Newsom directed CalRecycle (the state agency responsible for overseeing SB 54) to restart the regulations because of cost concerns for businesses and consumers. In response to Newsom's action, CalRecycle initiated a formal rulemaking for California’s plastic and packaging reforms and released draft regulations in August 2025 for public review and comment. The public comment period ended October 7, 2025.
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.
- Mid-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.
- 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 plastic single-use packaging must be recyclable.
- 2032: 25% source reduction in single-use plastic packaging and food service ware (compared to 2023 baseline).
- 2032: All single-use packaging must be recyclable or compostable.
Your Sustainable Packaging Partner
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As part of our support to customers in achieving their sustainable packaging goals, we provide an expansive suite of leading sustainability services ranging from market insights, lifecycle assessments, and recyclable stock solutions to custom packaging design, circularity road mapping, refillable and reusable packaging models, and sustainability communications strategies. Furthermore, we partner with like-minded organizations, partnership news article to address broad packaging issues and drive systemic change throughout the supply chain toward sustainable packaging practices.
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.