California Finalizes Packaging EPR Regulations Under SB 54

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California has finalized regulations implementing the state’s extended producer responsibility (EPR) program for packaging, more than a year after the governor directed CalRecycle to restart the rulemaking process over cost concerns.

The final rule, approved May 1, 2026, implements California’s Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54), passed in 2022.  Despite the delay, the program’s source reduction and recyclability targets remian unchanged:

  • 2027: 10% reduction in single-use plastic
  • 2028: 30% of single-use plastic recycled
  • 2030: 20% reduction in single-use plastic; 40% recycled
  • 2032: 25% reduction in single-use plastic; 65% recycled; 100% of packaging recyclable or compostable

On the same day, the state’s inaugural producer responsibility organization (PRO), Circular Action Alliance (CAA), published an illustrative fees document with low- and high-end fee estimates across covered material categories.  Producer fees will fund:

  • Program operating costs
  • Source reduction and reuse and refill initiatives
  • A requirement that the PRO remit $500 million annually to the state from 2027 through 2037

The next major milestone is June 15, 2026, when CAA will submit its draft program plan to the SB 54 advisory board.  CAA says it intends to publish final fee rates in the plan, which is expected to be finalized in October 2026.

CalRecycle has also published a webpage with guidance for producers, covering reporting obligations, covered material identification, and producer status determinations.  Additional guidance on exemptions, extensions, and exclusions is forthcoming.

Key Deadlines for Producers

According to CalRecycle, the May 1 final rule triggered a June 1, 2026, deadline for producers in California to do one of the following:

  • Register with CAA if participating in the approved PRO plan
  • Register with CalRecycle and apply as an independent producer if complying individually
  • Register with CalRecycle and apply for the small producer exemption if gross California sales were under $1 million in the most recent year

Another just-passed deadline was May 31 for producers in California to submit two 2025 reports: (1) an annual supply report with supply data by covered material category, and (2) an annual source reduction report covering source reduction activities.  Reports may be submitted to CAA or directly to CalRecycle through the agency’s new online portal, known as PEPRS.

In addition, producer-specific individual source reduction plans will be due sometime this summer, likely August 1.

Finally, May 31 was also the deadline for producers to submit simplified supply reports to CAA for Washington, Maryland, and Minnesota, reflecting an effort to standardize reporting deadlines across states with packaging EPR programs.

For more information, visit CAA’s website and CalRecycle’s SB 54 webpage.