California packaging EPR: SB 54

In short

If you own or license the brand on single-use packaging sold or distributed in California, you are likely the obligated producer under SB 54. Producers had to register by June 1, 2026, and the source-reduction baseline report was due July 1, 2026. Program fees start in January 2027. Registration and reporting run through Circular Action Alliance, the state's approved producer responsibility organization, or directly with CalRecycle. This is general information, not advice about your company: confirm every deadline with CAA or CalRecycle before acting, because dates can change.

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Who is obligated

Under SB 54, the producer is generally the manufacturer that owns or licenses the brand or trademark on covered packaging used in a commercial enterprise in California. If no such manufacturer is in California, the obligation falls to the California brand owner or exclusive licensee, and then to whoever sells or distributes the product in or into California. Out-of-state sellers shipping into California are covered. Agricultural commodities packaged where they are grown are excluded. (Cal. Public Resources Code 42041(w))

Key dates

June 1, 2026: Producer registration deadline (register with CalRecycle within 30 days of the permanent regulations taking effect May 1, 2026; join CAA or apply as an independent producer in the same window).
July 1, 2026: Source-reduction baseline report due to CalRecycle, covering 2023 plastic data.
January 2027: Program fees begin; CAA invoices producers in January with 45 days to pay.
July 1, 2027: Next annual data report due to CalRecycle, covering 2026 data. CAA requires its own annual supply reporting by May 31 each year.

Sources: CalRecycle regulations document; CalRecycle producer guidance

Where to file

Two paths. Most producers register with CAA and report supply data through CAA's producer reporting portal. Producers complying individually (or choosing to self-report) use CalRecycle's PEPRS portal directly. Every producer, including exemption applicants, must register with CalRecycle. (CalRecycle producer guidance)

Program and regulator

Circular Action Alliance is California's producer responsibility organization, selected by CalRecycle on January 5, 2024. CalRecycle is the state regulator: it adopted the permanent regulations, runs the PEPRS portal, approves CAA's program plan, and enforces compliance. CAA submitted its final program plan on October 13, 2026; once approved, the program begins on or before January 1, 2027. (CAA California)

Fees

CAA's October 2026 program plan includes proposed 2027 fee rates, explicitly described as good-faith estimates that become operative only if CalRecycle approves the plan. As an example from the plan's Table 5: clear PET bottles carry a base weight fee of $0.12 per pound, plus a reuse investment fee and a plastic pollution mitigation fee. Fees are eco-modulated, with malus fees on virgin plastic funding source-reduction bonuses. (CAA California program plan, Oct 2026)

Small-producer exemption

Producers with gross sales in California of less than $1,000,000 in the most recent calendar year may apply for a small-producer exemption. The exemption lasts two years and is renewable, but exempt producers must still maintain their CalRecycle registration. (14 CCR 18980.5.2)

Program targets

By January 1, 2032: 100% of packaging recyclable or compostable, 25% source reduction of plastic packaging, 65% recycling of single-use plastic packaging. Interim milestones start January 1, 2027 with a 10% single-use plastic reduction. Expanded polystyrene food service ware has been prohibited in California since January 1, 2025.

Frequently asked questions

Do I register with CAA or CalRecycle?

This is general information, not advice about your company. Most producers join CAA, which manages registration, reporting, and exemption submissions on their behalf. Producers complying on their own register and report directly with CalRecycle through PEPRS. Either way, you must be registered with CalRecycle.

Are the 2027 fee rates final?

This is general information, not advice about your company. No. The rates in CAA's October 2026 program plan are proposed estimates that become operative only if CalRecycle approves the plan. Do not budget on them as final.

I sell into California from another state. Am I covered?

This is general information, not advice about your company. Yes, likely. Sale is deemed to occur in California if the covered materials are delivered to the purchaser in the state, so out-of-state sellers shipping into California fall under SB 54.

How does NorthEPR help with California?

This is general information, not advice about your company. NorthEPR evaluates your packaging catalogue against SB 54's rules, estimates your fees from published schedules, and prepares draft reports you review and file yourself.

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