Permanent regulations for SB 54, California’s highly anticipated extended producer responsibility and packaging source reduction law, are now in effect.
The rules were approved by the Office of Administrative Law and filed with the secretary of state on Friday. That same day, producer responsibility organization Circular Action Alliance published illustrative fees for obligated producers in California.
“We’re taking action to stop producers from using excessive amounts of plastic packaging that pollutes our communities,” CalRecycle Director Zoe Heller said in a statement. “With strong state oversight, producers will be accountable for designing less wasteful packaging and funding systems to make sure their materials are collected, reused, and composted or recycled when consumers are done with them.”
Come 2032, producers must reduce their use of covered materials by 25%; ensure recycling rates of 65%; and ensure 100% recyclability or compostability for all single-use packaging and service ware. There are phased targets along the way.
The May 1 regulatory milestone was years in the making after Gov. Gavin Newsom signed SB 54 into law in 2022. In the time since, CalRecycle and an EPR advisory board have worked through needs assessments, covered material category lists and other key documents. Both CalRecycle and Circular Action Alliance have undergone multiple leadership changes.
Newsom delayed the finalization of SB 54 rules last March, calling on CalRecycle to rework the rules to better account for costs to businesses and consumers. Despite the setback, the SB 54 implementation dates and deadlines for producers remained unchanged.
CalRecycle has set up the Packaging Extended Producer Responsibility System, an online portal for producer registration, data submission and compliance tracking. Producers can either report through CAA — which manages registration, reporting and submissions on producers’ behalf — or self-report through the portal. CalRecycle says it intends to share additional producer guidance resources, including on identifying covered materials and determining producer status.
Outside groups that have been involved since SB 54’s early days in the California legislature reacted to Friday’s milestone.
“Getting implementation right is just as important as passing the policy itself,” said Heidi Sanborn, executive director and CEO of the National Stewardship Action Council, in a statement. “This is where the environmental, public health, and economic benefits are either realized or lost and where cost-effective systems must be designed to work in practice.”
CAA’s upcoming program plan, plus additional guidance from CalRecycle, will further illuminate the path forward for SB 54 implementation, said Anja Brandon, director of plastics policy at the Ocean Conservancy.
“At the end of the day, EPR is so iterative, and there’s so many unknown unknowns in this process,” Brandon said. “And so every time we are marching closer to the program rolling out and delivering on its promises is a really exciting step.”
These are some of the steps that come next:
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May 31, 2026CAA deadline for producers to submit 2025 annual supply and source reduction reports
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June 1, 2026CalRecycle deadline for producers to either a) register with/submit supply data to CAA, if participating in CAA’s plan; b) register with CalRecycle and apply to be an independent producer; or c) register with CalRecycle and apply for the small producer exemption, if qualifying
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June 15, 2026CAA submits draft program plan
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Oct. 1, 2026CAA’s program plan to be finalized with final fee rates
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March 1, 2027CAA submits first fees for California’s Plastic Pollution Mitigation Fund
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July 1, 2027CAA submits first administrative fees to CalRecycle