SB 54 Explained: California’s Packaging Extended Producer Responsibility Law

Author: Cambre Codington

California’s SB 54, the Plastic Pollution Prevention and Packaging Producer Responsibility Act, establishes one of the most sweeping packaging extended producer responsibility (EPR) programs in the United States. Companies that sell, distribute, or import covered packaging or single-use plastic food service ware into California now face near-term registration, reporting, and fee-related obligations under the law.

SB 54 shifts responsibility for covered packaging waste upstream, away from local governments and ratepayers and toward the companies that place covered materials into California’s economy. The law requires producers to report packaging data, participate in or otherwise comply with an approved producer responsibility program, and support California’s broader source reduction, recycling, and plastic pollution mitigation goals.

The California Department of Resources Recycling and Recovery (CalRecycle), the state agency responsible for recycling, waste reduction, and resource conservation programs, is responsible for implementing SB 54. In 2025 and 2026, CalRecycle advanced the program through formal rulemaking, including proposed permanent regulations, public comment periods, and revisions addressing implementation details and specific packaging categories. The California Office of Administrative Law (OAL) approved the permanent SB 54 regulations on May 1, 2026, and the regulations became effective upon filing.

CalRecycle has also approved Circular Action Alliance (CAA) as the Producer Responsibility Organization (PRO) for SB 54. A PRO is the entity producers create or join to design, fund, and operate the statewide EPR program. Under SB 54, the PRO is responsible for developing the program plan and budget and coordinating how covered materials will be collected, recycled, composted, or otherwise managed to meet the law’s requirements.

The regulation details can be found on CalRecycle’s SB 54 webpage, which also contains additional resources such as the guidance webpage for producers. CalRecycle is routinely updating these webpages with information on extensions, exemptions, and exclusions under the new law. This article summarizes what SB 54 requires, who may be considered a producer, key reporting and fee milestones, and practical steps companies can take now to prepare.

What is SB 54?

SB 54 is California’s EPR law for single-use packaging and single-use plastic food service ware. Covered material can include packaging associated with products sold, distributed, or imported into California, as well as certain plastic food service ware. Companies should evaluate not only primary packaging, but also secondary and transport packaging, labels, closures, coatings, and multi-material components. To confirm whether a specific product or packaging format is covered, companies should review CalRecycle’s Covered Material Categories List and related producer guidance.

At a high level, SB 54 requires producers to evaluate the amount, type, and characteristics of covered materials they place into the California market. This includes information related to packaging material categories, weights, and whether materials are recyclable or compostable under applicable program requirements.

SB 54 also includes a significant producer-funded mitigation requirement. Beginning in calendar year 2027, the PRO must remit a $500 million annual surcharge, totaling $5 billion over 10 years, for deposit into the California Plastic Pollution Mitigation Fund. The fund is intended to address plastic pollution impacts and support communities most affected by single-use waste. In practice, producers fund this obligation through fees paid to participate in the PRO.

What are SB 54’s major 2032 goals?

SB 54 establishes several statewide performance targets intended to reduce single-use plastic waste and improve packaging circularity. By 2032, the law requires the following outcomes:

1. 100% of covered packaging and plastic food service ware sold, distribute, or imported into California must be recyclable or compostable;
2. 65% of single-use plastic-covered material must be recycled; and
3. Single-use plastic packaging and single-use plastic food service ware must be reduced by 25% compared to the 2023 baseline.

CalRecycle established the source reduction baseline using 2023 data, including the weight and number of plastic components. These targets make SB 54 particularly significant because they combine traditional EPR funding and reporting obligations with broader source reduction and recyclability or composability requirements.

Who is considered a “producer” under SB 54?

Determining producer status under SB 54 can be complex and may vary by product line, brand, supply chain structure, and how covered material enters California commerce.

Under the California Public Resources Code, the producer is generally the person or entity that manufactures a product using covered material and owns or licenses the brand or trademark under which the product is sold, offered for sale, distributed, or used in California.

If that entity is not located in California, producer responsibility may shift to another entity in the supply chain. Depending on the product and transaction structure, the producer may be:

• The brand owner;
• The trademark or license holder;
• The importer;
• The distributor; or
• The seller offering the product into California.

SB 54 also includes certain exclusions. For example, a producer does not include a person who produces, harvests, and packages an agricultural commodity on the site where the agricultural commodity was grown or raised.

In practice, SB 54 may affect California-based brands as well as out-of-state brand owners, trademark or license holders, importers, distributors, retailers, and certain sellers shipping products into California. Companies should not assume that producer responsibility falls on the same entity for every product. Instead, producer status should be evaluated at the product, SKU, or product-family level.

CalRecycle has provided guidance and a producer determination flowchart to help entities evaluate whether they may be considered producers under SB 54. CalRecycle’s economic analysis estimates that thousands of non-exempt producers may be responsible for funding SB 54 implementation costs.

What are the compliance pathways for producers?

Producers generally must take one of three compliance pathways:

1. Register with and participate in the approved PRO, Circular Action Alliance;
2. Register with CalRecycle and apply to comply as an independent producer; or
3. Register with CalRecycle and apply for a small producer exemption, if eligible.

For many producers, participation in CAA will likely be the primary compliance pathway. Producers that intend to comply independently or seek an exemption should carefully review CalRecycle guidance and supporting documentation requirements.

What are the reporting deadlines and fee milestones?

Because the permanent regulations became effective on May 1, 2026, producers have until June 1, 2026, to take one of the required initial actions mentioned above. Entities that become producers after June 1, 2026, but before January 1, 2027, must register within 30 days of becoming a producer. Entities that become producers after January 1, 2027, must register within six months of becoming a producer.

CalRecycle has developed the Packaging Extended Producer Responsibility System (PEPRS), which serves as the online portal for producer registration, data submission, and compliance tracking. Through PEPRS, producers may register and submit applications to comply independently or seek an exemption, as applicable.

Key near-term milestones include:

Reporting entities should expect to provide data related to covered material categories, material weights, units sold or distributed into California, recyclability or compostability status, and supporting documentation. Producers that voluntarily submitted baseline data in 2025 may need to review and revise prior submissions to align with current requirements.

Producers that fail to register, report, or comply through the PRO or on an individual basis may face enforcement action and penalties by CalRecycle.

How will producer fees be determined?

SB 54 requires producers to fund program implementation and contribute to the California Plastic Pollution Mitigation Fund. Beginning in 2027, the PRO must remit $500 million per year for 10 years, totaling $5 billion.

The PRO will establish fee rates for participant producers based on plan factors such as implementation costs, PRO operating costs, reimbursement costs to CalRecycle, and each producer’s share of covered materials. The PRO must also develop a methodology to calculate each participant producer’s market share and corresponding environmental mitigation surcharge assessment.

CAA is expected to continue refining fee schedules and methodologies as implementation progresses. Producers should monitor CAA and CalRecycle updates closely as more information becomes available regarding fee transparency, reporting categories, and data quality expectations.

How can companies prepare for SB 54?

Although implementation may continue to evolve, companies can begin preparing now by organizing packaging data, evaluating producer status, and identifying compliance gaps. Early preparation can reduce reporting burden, improve defensibility, and help companies make informed packaging design decisions before deadlines become urgent.

ALL4 recommends that companies consider the following steps:

• Determine who the producer is for each product line, SKU, or product family;
• Register under the appropriate compliance pathway and take timely action through CAA or CalRecycle;
• Build a packaging inventory that captures material types, units sold or distributed into California, and applicable covered material categories;
• Include labels, coatings, closures, secondary packaging, transport packaging, and multi-material items in the packaging inventory;
• Identify high-risk packaging formats that may face recyclability, compostability, or source reduction challenges;
• Create a change-control process so packaging redesigns do not inadvertently create new compliance issues;
• Evaluate whether existing packaging data systems can support annual reporting; and
• Track CalRecycle and CAA guidance as additional resources, reporting instructions, and implementation updates are released.

Packaging EPR compliance challenges often stem from the amount and type of packaging material used, as well as the difficulty of collecting accurate data from suppliers and internal systems. Companies that prepare early can reduce long-term compliance burden, make smarter packaging design choices, and build repeatable systems that scale as other states adopt similar EPR programs.

Companies that wait may face higher compliance costs, compressed decision-making timelines, and greater reliance on suppliers to reconstruct packaging composition and weight data after the fact.

How can ALL4 help?

ALL4’s sustainability and digital solutions professionals can support companies as they assess and respond to California’s SB 54 and broader packaging EPR requirements. Our team can help evaluate producer obligations across complex supply chains, develop packaging inventories and reporting systems, support PRO engagement, assess exemption or independent compliance pathways, and build practical source-reduction strategies aligned with SB 54’s long-term targets.

For questions about California SB 54 or broader packaging EPR compliance planning, please contact Cambre Codington at ccodington@all4inc.com or your ALL4 Project Manager.