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California SB 54: What Food and Beverage Producers Need to Know Before 2027 Fees Begin

V. Jain · · 3 min read

California SB 54 fees begin 2027 - NorthEPR guide

California SB 54: What Food and Beverage Producers Need to Know Before 2027 Fees Begin

If you sell packaged food or beverages in California, a new law is about to put a price on every SKU you ship. California's SB 54, the Plastic Pollution Prevention and Packaging Producer Responsibility Act, shifts the cost of packaging waste onto producers. Registration and reporting are already underway, and fee payments begin in 2027.

Here is what matters, in plain language.

Who counts as a "producer"?

SB 54 defines the producer through a hierarchy. The first one that applies is responsible:

  1. The brand owner
  2. The licensee
  3. The importer
  4. The retailer (only if none of the above apply)

For most food and beverage brands, that means you. If your name is on the package and it is sold in California, you are very likely the obligated producer. There is a small-producer exemption for companies with under $1 million in annual gross sales in California, but the bar is low and most growing brands clear it.

The timeline that matters

  • June 2022: SB 54 signed into law.
  • January 2024: CalRecycle selected the Circular Action Alliance (CAA) as the state's Producer Responsibility Organization.
  • September 2025: Producer registration deadline with CAA.
  • November 2025: Initial producer reporting deadline (2023 packaging data).
  • May 2026: Annual supply report and source reduction report due.
  • January 2027: The EPR program begins. Fee assessments start.
  • March 2027: First payments into the California Plastic Pollution Mitigation Fund.
  • 2032: 65% of single-use plastic packaging must be recyclable; 25% source reduction against the 2023 baseline; all packaging recyclable or compostable.

The 2023 data you report now becomes the baseline that fees and reduction targets are measured against. Getting it wrong now compounds for a decade.

What will it cost?

Fees are eco-modulated, which means the material and design of your packaging determines what you pay. Hard-to-recycle formats cost more. Recyclable, lightweight, recycled-content packaging costs less. On top of producer fees, the program collects $500 million per year from 2027 to 2037 for the Plastic Pollution Mitigation Fund.

Non-compliance is not a rounding error. CalRecycle can pursue penalties of up to $50,000 per day, plus restrictions on selling your products in California.

What to do right now

  1. Confirm you are covered. Walk the producer hierarchy for every brand you sell in California.
  2. Register with CAA if you have not already. Each legal entity registers separately.
  3. Build your packaging inventory. Every SKU, every component, every material, with weights. This is the data the fees are calculated from.
  4. Audit your 2023 baseline. It is already reported or due; errors here follow you to 2032.
  5. Model your 2027 fees. Run your packaging mix against the fee logic now, while you still have time to redesign.
  6. Start source reduction. A 10% plastic reduction target hits in 2027 against the 2023 baseline.

The hard part is the data

Most producers we talk to do not have a clean, SKU-level packaging inventory. The data lives across suppliers, spec sheets, and spreadsheets, and nobody owns it. That is exactly what makes the 2027 fee calculations painful.

We built NorthEPR to fix that: software that helps food and beverage producers figure out where they have to report, what they owe, and get their filings ready on time. We are opening 3 free pilot spots for a 2026 packaging-data health check plus first filing support. If California is on your radar, take a look at the pilot.