California’s 2026 Baseline Packaging Data Reports
California’s EPR rulemaking is about to create a compressed, two-step reporting cycle for producers, and packaging teams need to plan now for a February 2026 “baseline update” of their original 2025 baseline submission back in November.
Why California’s 2026 Packaging Data Baseline Report Matters
California’s packaging EPR regulations are expected to be approved around January 9, 2026, which starts a 30-day countdown for producers to file an updated 2026 Baseline Producer Report. This second baseline is not a new dataset, it still uses 2023 data as required by the regulation, it is an adjustment step triggered by the finalization of regulations so producers can align their figures with any last-minute regulatory changes.
For producers, the 2025 baseline you submitted first is being used by the Circular Action Alliance (CAA) to build and refine the program plan due to the state in June, and the state required 2026 baseline update is your opportunity to make sure your official numbers match the final regulation.
2025 vs. 2026 California Baseline Reports
The key distinction between the 2025 and 2026 California baseline reports is timing, not scope. Both rely on supply packaging data from the 2023 calendar year, capturing what packaging you placed on the California market, but they are anchored to different milestones in the regulatory process.
- The 2025 California Baseline Producer Report was due to CAA by November 15, 2025, so the PRO has enough time to consolidate data and build its program plan for submission by June 15.
- The 2026 California Baseline Producer Report is a separate filing required by the state due within 30 days after the regulations are finalized, most likely in February 2026.
In practice, producers will need to revisit their 2023 data after the regulations are approved and either confirm “my data is good” or adjust it to reflect new definitions, categorizations, or thresholds introduced in the final ruling.
What To Do Next
Once the regulations are finalized, producers will log into the California reporting portal and treat the 2026 baseline as a confirmation and correction step. If the original 2025 baseline aligns with the final requirements, the producer still needs to submit that confirmation as a distinct report; if not, they must update the data and resubmit within the same tight 30-day window.
Operationally, this puts pressure on data governance. Producers should come into 2026 with a clean, well-documented baseline dataset and clear ownership across finance, sustainability, and packaging teams so that any required tweaks to component mapping, material definitions, or scope can be made quickly. Treating the 2025 baseline as a dress rehearsal and the 2026 baseline as the audited version tied to finalized regulations. This will help avoid last-minute scrambles and potential compliance gaps.
How To Get Help with Packaging Data Reporting and EPR Compliance in California
RLG is a global provider of EPR compliance services, with staff located in the United States, including California. Strong relationships with regulators, plus over 30 years of experience, puts RLG at the forefront of compliance, and our sterling reputation is fueled by our commitment to decreasing risk.
We also offer packaging data management, with data collection and analysis, and our packaging database has over 60 million SKUs that can be leveraged for accuracy in reporting.
We welcome you to contact us today.
