California's long-awaited permanent regulations for Senate Bill 54 (SB 54), the producer responsibility and packaging source reduction law, are now officially in effect. The regulations were approved by the Office of Administrative Law and filed with the Secretary of State last Friday. On the same day, the producer responsibility organization Circular Action Alliance (CAA) released sample fees for obligated producers in California.

"We are taking action to stop producers from polluting our communities with excessive plastic packaging," CalRecycle Director Zoe Heller said in a statement. "Under strong state oversight, producers will be responsible for designing packaging that wastes less and funding systems to ensure their materials are collected, reused, composted, or recycled after consumer use."

Under the regulations, by 2032, producers must reduce the use of covered materials by 25%; achieve a recycling rate of 65%; and ensure that all single-use packaging and food service ware is 100% recyclable or compostable. The regulations also set phased targets.

This May 1 regulatory milestone took years to achieve. In 2022, Governor Gavin Newsom signed SB 54 into law. Since then, CalRecycle, along with an EPR advisory committee, has progressively completed needs assessments, lists of covered material categories, and other key documents. During this period, both CalRecycle and the Circular Action Alliance experienced multiple leadership changes.

Last March, Newsom delayed the finalization of SB 54 rules, asking CalRecycle to recalibrate the rules to better account for costs to businesses and consumers. Despite this setback, the implementation date of SB 54 and producer deadlines have not changed.

CalRecycle has established the "Packaging Producer Responsibility System," an online portal for producer registration, data submission, and compliance tracking. Producers can report through CAA, which manages registration, reporting, and submissions on their behalf, or self-report through the portal. CalRecycle stated it plans to provide additional producer guidance resources, including how to identify covered materials and determine producer status.

External groups that have been involved with SB 54 since its early stages in the California legislature responded to last Friday's milestone.

"Proper implementation is just as important as passing the policy itself," Heidi Sanborn, Executive Director and CEO of the National Stewardship Action Council, said in a statement. "Environmental, public health, and economic benefits are either realized or lost here; cost-effective systems must be designed to work in practice."

Anja Brandon, Director of Plastics Policy at the Ocean Conservancy, said that CAA's upcoming program plan, along with further guidance from CalRecycle, will further clarify the path forward for SB 54 implementation.

"At the end of the day, EPR is a highly iterative process with many unknown unknowns," Brandon said. "So every time we get closer to program launch and delivering on its promises, it's an exciting step."

Here are some of the next key steps:

  • May 31, 2026:Deadline for producers to submit 2025 annual supply and source reduction reports to CAA.
  • June 1, 2026:Deadline for producers to complete the following: a) register with CAA and submit supply data if participating in the CAA program; b) register with CalRecycle and apply as an independent producer; or c) register with CalRecycle and apply for a small producer exemption if eligible.
  • June 15, 2026:CAA submits draft program plan.
  • October 1, 2026:CAA finalizes its program plan and sets final rates.
  • March 1, 2027:CAA submits first fees to the California Plastic Pollution Mitigation Fund.
  • July 1, 2027:CAA submits first administrative fees to CalRecycle.