Summary
Details
- California
Covered producers generally must:
Register.
Participate in the PRO or obtain authorization for independent compliance.
Report covered material.
Finance EPR implementation.
Support source reduction.
Support recycling.
Meet applicable material requirements.
Follow PRO and CalRecycle rules.
SB 54 contains exclusions for certain types of material and regulatory situations.
The implementing regulations also provide mechanisms concerning:
Small producer exemptions.
Extensions.
Covered material exclusions.
Independent producer compliance.
Specific statutory exemptions.
Companies should not assume exemption solely because they are small or because packaging is already regulated under another California program.
Deep dive
- What’s Required
- 1. Determine producer status
- 2. Identify covered material
- 3. Participate in a Producer Responsibility Organization
- 4. Reduce single-use plastic
- 5. Meet plastic recycling targets
- 6. Ensure packaging is recyclable or compostable
- 7. Finance the EPR system
- 8. Report covered material data
- 9. Expanded polystyrene restrictions
- 10. Meet PRO plan requirements
- Important Deadlines
- Current Status
- Penalties for Non-Compliance
- Examples of Known Violations / Failure Modes
- Resources
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What’s Required
1. Determine producer status
The law generally places responsibility on producers of covered material, although the legal producer can vary according to:
Brand ownership.
Manufacturing arrangements.
Import arrangements.
Licensing relationships.
Product category.
Packaging ownership.
Companies need to assess the statutory hierarchy rather than assume the physical packaging manufacturer is always responsible.
2. Identify covered material
Covered material includes:
Single-use packaging.
Single-use plastic food-service ware.
CalRecycle divides covered materials into categories involving:
Glass.
Ceramics.
Metal.
Paper and fiber.
Plastic.
Wood and other organic materials.
3. Participate in a Producer Responsibility Organization
Most producers must participate in the approved Producer Responsibility Organization.
Circular Action Alliance currently serves as California’s first approved PRO.
Alternatively, qualifying producers may apply to comply independently where statutory and regulatory conditions are met.
4. Reduce single-use plastic
The law establishes progressively increasing source-reduction targets:
Deadline | Required reduction |
|---|---|
January 1, 2027 | 10% |
January 1, 2030 | 20% |
January 1, 2032 | 25% |
Reduction can involve measures including:
Eliminating unnecessary packaging.
Lightweighting.
Reuse.
Refill.
Concentrated product formats.
Packaging redesign.
5. Meet plastic recycling targets
Plastic-covered materials must reach:
Deadline | Recycling target |
|---|---|
January 1, 2028 | 30% |
January 1, 2030 | 40% |
January 1, 2032 | 65% |
6. Ensure packaging is recyclable or compostable
By January 1, 2032, 100% of covered packaging and plastic food-service ware sold in California must be recyclable or eligible to be labeled compostable under applicable requirements.
7. Finance the EPR system
Producers finance the collection, recycling, and system improvements necessary to achieve SB 54 goals through the PRO framework and applicable producer fees.
The legislation also requires producers collectively to provide US$500 million annually for ten years beginning in 2027, totaling US$5 billion, to address environmental impacts associated with plastic pollution.
8. Report covered material data
Producers must provide information concerning:
Covered materials placed on the market.
Material type.
Packaging form.
Weight.
Recycling.
Reuse.
Source reduction.
Exemptions or exclusions where applicable.
CalRecycle operates the Packaging EPR reporting system for registration and regulatory submissions.
9. Expanded polystyrene restrictions
SB 54 establishes separate recycling-rate conditions for expanded polystyrene food-service ware.
To continue supplying EPS food-service ware in California from January 1, 2025, producers needed to demonstrate that EPS achieved a 25% recycling rate.
CalRecycle states that this threshold was not met. As a result, EPS food-service ware producers are currently prohibited from selling, offering for sale, distributing, or importing covered EPS food-service ware into California.
10. Meet PRO plan requirements
The PRO must develop a comprehensive plan covering:
Producer participation.
Source reduction.
Recycling infrastructure.
Collection.
Processing.
Consumer education.
Reuse.
Reporting.
Funding.
Performance monitoring.
Circular Action Alliance submitted its PRO Plan to the advisory board on June 15, 2026.
Important Deadlines
June 30, 2022: SB 54 signed into law.
January 1, 2023: Law became effective.
July 1, 2024: CalRecycle published required covered material categories.
January 1, 2025: Initial 25% EPS food-service ware recycling threshold.
December 31, 2025: CalRecycle published updated covered material categories and recycling-rate determinations.
May 1, 2026: Permanent SB 54 regulations approved and became effective.
June 15, 2026: First PRO Plan submitted to the Advisory Board.
January 1, 2027: 10% single-use plastic source reduction target.
2027: Producer environmental mitigation payments of US$500 million annually begin.
January 1, 2028: 30% plastic recycling target.
January 1, 2030: 20% source reduction and 40% plastic recycling targets.
January 1, 2032: 25% source reduction, 65% recycling and 100% recyclable or compostable covered packaging targets.
Current Status
Active and legally binding.
SB 54 entered a major new implementation phase in 2026.
The Office of Administrative Law approved the permanent regulations on May 1, 2026, and they became effective immediately. CalRecycle has since published updated producer guidance, exemption information, and implementation materials.
Circular Action Alliance is the approved PRO and submitted its initial producer responsibility plan in June 2026.
Penalties for Non-Compliance
CalRecycle has authority to enforce the Act.
Enforcement tools can include:
Investigations.
Notices of violation.
Administrative penalties.
Corrective orders.
Restrictions on sale.
Producer-registration consequences.
Enforcement against unsupported exemptions.
Enforcement against EPS food-service ware supplied contrary to statutory restrictions.
Examples of Known Violations / Failure Modes
Failing to identify producer status.
Failing to register under SB 54.
Failing to join the approved PRO.
Supplying covered material without required reporting.
Underreporting packaging quantities.
Incorrectly classifying covered material.
Double counting source reduction.
Claiming packaging is recyclable when CalRecycle has determined otherwise.
Incorrectly claiming a small-producer exemption.
Failing to support required recycling or reuse activities.
Selling prohibited EPS food-service ware.
Missing producer-reporting requirements.
Failing to pay applicable producer fees.
Treating participation in the PRO as automatic proof that packaging complies with all California environmental requirements.
Resources
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