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Packaging rule · United States · EPR

California SB 54 packaging EPR and permanent regulations

Extended producer responsibility (EPR) rule covering plastic, paper and board, metal, glass in California, United States, set by California Legislature / CalRecycle. Applies since 1 May 2026.

By the SPI teamRule ID PR-US-004Source consulted 14 October 2026Verified 14 October 2026
Sourced facts

The rule

Recorded from the official source named below. Rates and dates are as the source states them on the date it was consulted.

Jurisdiction
United States · California
Authority
California Legislature / CalRecycle
Rule type
EPR
Materials
Plastic, Paper and board, Metal, Glass
Status
In force Enacted
Adopted or published
30 June 2022
Applies from
1 May 2026
From the source

“on May 1, 2026, the Office of Administrative Law (OAL) approved the permanent regulations”

Official source CalRecycle: SB 54 Permanent Regulations approved and in effectOfficial (government or regulator) · consulted 14 October 2026

Deadlines

Key dates

  1. Adopted or published 4 years and 3 months ago

  2. Applies from 5 months ago

  3. Source consulted by the SPI team 1 day ago

  4. Re-checked by a second SPI team member 1 day ago

SPI analysis

What it means

SPI analysis Our reading of the official source above. Not legal advice; always rely on the official text.

SPI summary

SB 54 requires producers of single-use packaging and plastic food service ware to join a PRO (Circular Action Alliance) and meet 2032 source reduction, recycling and recyclability goals. Permanent regulations were approved on 1 May 2026, and registration requirements applied by 1 June 2026.

In practice

California's SB 54 permanent regulations took effect on filing on 1 May 2026, and producers of single-use packaging and plastic food service ware had until 1 June 2026 to choose a path: join Circular Action Alliance (CAA) and report supply data, register as an independent producer, or apply for the small producer exemption. Registration, reporting and compliance run through CalRecycle's PEPRS portal. CAA submitted its PRO plan to the Advisory Board on 15 June 2026, and the law's goals run to 2032.

Where the record is unclear

  • SPI has not yet confirmed the 2032 percentage targets (source reduction, recycling rate, recyclability) as text on the CalRecycle page.
  • The record says the CAA programme plan is due in October 2026; CalRecycle shows submission to the Advisory Board on 15 June 2026 but no approval or due date.
  • Fee start dates are not stated on the pages consulted.

Where it sits in the tracker

  • One of 13 packaging rules we track in the United States, of which 7 are EPR rules.
  • In all, 25 EPR rules are tracked across 15 jurisdictions. Compare them below

Company profiles that map to this rule

Companies whose SPI profile lists this rule in its regulatory exposure, based on where they report selling. Not company-reported.

SPI analysis

Overview

The Plastic Pollution Prevention and Packaging Producer Responsibility Act is SB 54 (Allen, Chapter 75, Statutes of 2022), signed on 30 June 20226. It sits in Division 30, Part 3, Chapter 3 of the Public Resources Code, with covered material rules in PRC 42061 and PRO approval in PRC 42061.52. CalRecycle's stated rationale is that packaging makes up over 50% by volume of what California sends to landfill2.

The Act combines a classic PRO model with hard outcome targets. By 1 January 2032, single-use plastic must be cut by 25% and recycled at 65%, and all covered packaging must be recyclable or compostable, with interim steps of 10% source reduction in 2027, 30% recycling in 2028, and 20% reduction and 40% recycling in 20304. Plastic producers also fund the Plastic Pollution Mitigation Fund under PRC 42064: $500 million a year for ten years from July 2027, split 60% to environmental justice and public health impacts and 40% to environmental impacts5.

The permanent regulations, approved by the Office of Administrative Law and effective on filing on 1 May 2026, made the programme operational1. They launched PEPRS, CalRecycle's portal for registration, reporting and compliance monitoring, and gave producers until 1 June 2026 to choose one of three paths1.

Duties

Who must do what

Producer of single-use packaging or plastic food service ware (PRC 42041(w))

  • By 1 June 2026, register with Circular Action Alliance and submit supply data, register with CalRecycle as an independent producer, or apply for the small producer exemption1.
  • As an independent producer, operate under a CalRecycle-approved plan (14 CCR 18980.7) and show the recycling rate and source reduction outcomes that apply to its covered material4.
  • Contribute, as a producer of single-use plastic packaging or foodware, to the $500 million a year mitigation payments from July 2027 (PRC 42064)5.

Circular Action Alliance

  • Act as the first PRO approved under PRC 42061.5; it submitted its PRO plan to the Advisory Board on 15 June 20262.
  • Handle registration, reporting and certain exemptions and exclusions for member producers through PEPRS4.

CalRecycle

  • Approve the PRO plan, budget and annual reports, publish the source reduction baseline, and publish the covered material categories list, last updated on 31 December 2025 with the first recycling rate per category2.
  • Appoint the Advisory Board, which next meets on 16 October 2026 in Sacramento2.
Scope

Are you in scope?

Work through each question. The answers are the SPI team's reading of the sources cited.

  1. Were your gross annual sales under $1 million?

    If yes
    You may apply through PEPRS for the temporary, renewable small producer exemption under 14 CCR 18980.5.2, but you must still plan for recyclable or compostable packaging by 20323.
    If no
    Choose the PRO or independent producer path1.
  2. Do you produce, harvest and package an agricultural commodity on the same site where it was grown or raised?

    If yes
    PRC 42041(w)(4) excludes you from the producer definition3.
    If no
    Apply the producer definition in PRC 42041(w).
  3. Is the item a small packaging component that does not hinder recycling and is not plastic food service ware?

    If yes
    It may be a de minimis component under 14 CCR 18980.2.2 and not covered material3.
    If no
    It is covered material.
  4. Does the item reach a 65% recycling rate (70% from 2027) outside curbside collection?

    If yes
    With CalRecycle approval it may fall outside covered material under 14 CCR 18980.2.33.
    If no
    The full obligations apply.
  5. Would SB 54 conflict with a federal rule for your food or agricultural commodity packaging?

    If yes
    File a complete exclusion notice under 14 CCR 18980.2(a)(2), following CalRecycle's 27 August 2026 guidance3.
    If no
    Most other excluded materials need no submission3.
Checklist

Compliance checklist

  1. Confirm the path chosen by 1 June 2026

    By Now

    SPI analysis of the official text. Not legal advice; confirm with the text or counsel. Producers had 30 days from 1 May 2026, extended to 1 June because day 30 fell on a Sunday, to join the PRO, register as independent or apply for exemption1.

    Evidence to keep PEPRS registration record or CAA confirmation.

  2. Map SKUs to covered material categories

    By Now

    Use the 31 December 2025 list and CalRecycle's September 2025 reporting guidance on covered material categories24.

    Evidence to keep SKU-to-category table with weights.

  3. Build the source reduction baseline

    By Before 1 January 2027

    CalRecycle issued source reduction reporting guidance on 4 August 2026; the first 10% plastic reduction step falls on 1 January 20274.

    Evidence to keep Baseline plastic weight and unit counts by category.

  4. File federal-conflict exclusion notices

    By As needed

    Food and agricultural commodity packaging needs a complete notice explaining the federal conflict and the lack of alternatives3.

    Evidence to keep Notice and CalRecycle completeness confirmation.

  5. Review the next category list

    By 1 January 2027

    CalRecycle will update recyclability and compostability determinations, informed in part by new data on non-CRV cartons2.

    Evidence to keep Change log of category reassignments.

  6. Follow the PRO plan review

    By 16 October 2026 Advisory Board meeting

    The PRO plan submitted on 15 June 2026 will set producer fees and source reduction measures once CalRecycle approves it2.

    Evidence to keep Notes on plan provisions affecting fees.

Enforcement

Enforcement and penalties

Who enforces
CalRecycle, with the Attorney General enforcing related unfair competition claims26
Powers
CalRecycle monitors compliance through PEPRS registration, reporting and document submittals1.
Enforcement so far
The Attorney General's 2 December 2025 advisory, addressed to makers and brand owners of EPS foodware, cited PRC 42081(a) together with Unfair Competition Law civil penalties of up to $2,500 per violation6.

Penalties

BreachPenaltyLegal basis
Violation of SB 54 (administrative penalty)up to $50,000 per day, per violationPublic Resources Code section 42081(a)6

The per-day, per-violation structure means a producer that skipped the 1 June 2026 registration step accrues exposure daily16. The Attorney General's EPS advisory shows the state is prepared to pair SB 54 penalties with unfair competition claims6.

Connections

How it fits with other rules

Timeline

History of the rule

  1. Governor signs SB 54 (Chapter 75, Statutes of 2022)6.

  2. Deadline for CalRecycle's first covered material categories list2.

  3. CalRecycle publishes the updated category list with first recycling rate determinations2.

  4. Permanent regulations approved by OAL and effective on filing; PEPRS launched1.

  5. Producer deadline to join the PRO, register as independent or apply for exemption1.

  6. Circular Action Alliance submits its PRO plan to the Advisory Board2.

  7. Today

  8. Advisory Board meeting at CalEPA headquarters2.

  9. Next category list due; 10% single-use plastic reduction step24.

  10. First year of $500 million mitigation fund payments5.

  11. 25% source reduction, 65% plastic recycling and 100% recyclable or compostable packaging4.

Questions

Questions

What are California's SB 54 targets?

By 1 January 2032, single-use plastic must be reduced by 25% and recycled at 65%, and all covered packaging must be recyclable or compostable. Interim steps are 10% reduction in 2027, 30% recycling in 2028, and 20% reduction with 40% recycling in 20304.

What did producers have to do by 1 June 2026?

Choose one of three paths: join Circular Action Alliance and submit supply data, register with CalRecycle as an independent producer, or apply for the small producer exemption. The regulations took effect on 1 May 2026 and allowed 30 days, which ran to 1 June1.

Who qualifies as a small producer under SB 54?

A producer with gross annual sales under $1 million may apply for the exemption under 14 CCR 18980.5.2 through PEPRS. The exemption is temporary and renewable, and packaging must still be recyclable or compostable by 20323.

What is the Plastic Pollution Mitigation Fund?

Under PRC 42064, producers of single-use plastic packaging and foodware pay $500 million a year for ten years, starting in July 2027. 60% goes to environmental justice and public health impacts and 40% to environmental impacts5.

What penalties apply under SB 54?

PRC 42081(a) allows administrative penalties of up to $50,000 per day, per violation. The Attorney General's 2 December 2025 advisory on EPS cited this provision6.

Glossary

Definitions

Covered material
Single-use packaging and single-use plastic food service ware, as defined in PRC 42061 and grouped in CalRecycle's covered material categories list12.12
Independent producer
A producer complying individually under a CalRecycle-approved plan instead of through the PRO (14 CCR 18980.7)4.4
De minimis component
A single-use packaging component that meets the 14 CCR 18980.2.2 criteria, such as not hindering recyclability, and is therefore not covered material3.3
PEPRS
The Packaging Extended Producer Responsibility System, CalRecycle's portal for registration, reporting and compliance monitoring, launched on 1 May 20261.1
Sources

Sources for this analysis

  1. CalRecycle: SB 54 Permanent Regulations approved and in effect (bulletin, 1 May 2026) Regulator · Consulted 14 October 2026
  2. CalRecycle: Packaging EPR (SB 54) Regulator · Consulted 14 October 2026
  3. CalRecycle: Extensions, Exemptions, and Exclusions Regulator · Consulted 14 October 2026
  4. CalRecycle: Producer Guidance Regulator · Consulted 14 October 2026
  5. CalEPA: SB 54 Plastic Pollution Mitigation Fund Official · Consulted 14 October 2026
  6. California Attorney General: Enforcement advisory to producers of EPS food service ware under SB 54 (2 December 2025) Official · Consulted 14 October 2026
  7. Oregon DEQ: Producer Obligations Summary, Recycling Modernization Act Regulator · Consulted 14 October 2026

Written by the SPI team on 14 October 2026. Sources checked as of 14 October 2026. SPI analysis, not legal advice; always rely on the official text.

Audit trail

Change history

Verified: a second SPI team member re-checked every fact above against the source on 14 October 2026. Any later change to the facts sends the rule back to Sourced and is logged here.

  1. Verified by a second SPI team member

  2. Changed: rate note

  3. Verified by a second SPI team member

  4. Added to the tracker

Spotted an error? Write to sales@strategicpackaginginsights.com quoting PR-US-004 and the source. Corrections are logged in this history.

Other jurisdictions

EPR rules elsewhere

The same type of rule for the same materials in other jurisdictions, by the date it applies.

RuleWhereTypeMaterialsStatusApplies from
Containers and Packaging Recycling ActPR-JP-002JapanEPRPlastic, Paper and board, GlassIn force1 April 1997
Packaging EPR (Resolution 1407 of 2018)PR-CO-001ColombiaEPRAll packagingIn force2 August 2018
Extended Producer Responsibility Regulations and paper and packaging schemePR-ZA-001South AfricaEPRAll packagingIn force5 May 2021
EPR Guidelines for plastic packaging (PWM Rules Schedule II)PR-IN-001IndiaEPRPlasticIn force16 February 2022
Reverse logistics recycling credit certificates (Decree 11.413/2023)PR-BR-001BrazilEPRAll packagingIn force14 April 2023
Packaging collection and recovery targets under Ley REP (DS 12/2020)PR-CL-001ChileEPRAll packagingIn force16 September 2023
Sustainable Waste Management (EPR) Regulations, 2024PR-KE-002KenyaEPRAll packagingIn force4 November 2024
Quebec modernized selective collection (EPR) systemPR-CA-006Quebec, CanadaEPRAll packagingIn force1 January 2025
UK packaging EPR regulations (pEPR) 2024PR-GB-002United KingdomEPRAll packagingIn force1 January 2025
Ontario Blue Box Regulation (O. Reg. 391/21) full producer responsibilityPR-CA-003Ontario, CanadaEPRPlastic, Paper and board, Metal, GlassIn force1 January 2026

Every EPR rule in the tracker

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