Producer responsibility organization Circular Action Alliance (CAA) is less than three months away from submitting its program plan in California, even though the final SB 54 regulations have not yet been finalized and portions of the needs assessment report were just released.

At the SB 54 Advisory Committee meeting held last Friday, CAA staff reported on progress. Emily Coven, CAA's California lead, said, "We plan to submit the program plan to this advisory committee on June 15." She added that the 60-day public comment period will begin on June 15, and encouraged early submission of comments. "So, this is your summer beach reading—the SB 54 program plan," Coven said.

CalRecycle last week resubmitted the SB 54 regulations (California's extended producer responsibility and source reduction law) to the state Office of Administrative Law for approval, as CAA noted in a LinkedIn post on Monday. This follows multiple delays and withdrawals of the regulations. The Office of Administrative Law has 30 business days to approve or reject them.

Coven said some insights from the needs assessment may be incorporated into the program plan, but since CAA is deep into the editing and review process, these items are more likely to be handled separately in an appendix.

CAA noted that once the SB 54 regulations are approved, producers will have 30 days to report their 2023 baseline supply data to CAA. The producer responsibility organization expects the reporting deadline could fall sometime in May.

To date in California, CAA has received more than 2,000 producer reports covering 95 covered material categories, which include 2023 baseline data that can be used for source reduction planning, Shane Buckingham, CAA's chief of staff, shared at the meeting. CAA still needs at least 700 more reports.

"Right now, we are using the needs assessment research to estimate baselines. So, we are continuing our data modeling work and are developing source reduction plans," Buckingham said. He also stated that CAA plans to publish estimated fee rate ranges on May 1 so producers can begin preparing for 2027 budgets.

Some producers have not yet submitted reports. "Some producers have said they will not submit until the final regulations are issued," Buckingham said. "Despite the regulatory uncertainty, the producer community has shown very positive engagement because they really want to be prepared. But there are still many producers waiting for regulatory clarity."

Similar to CAA's implementation of future packaging EPR programs in several other states, California will also have a May 31 reporting deadline this year to inform fees for future years. That deadline will require supply and source reduction reports based on 2025 data.