Update: California SB 54 Packaging EPR
Circular Action Alliance (CAA) has released a new California Program Update summarizing key developments under SB 54, the state’s packaging Extended Producer Responsibility (EPR) law.
CalRecycle has published the SB 54 Material Characterization Study, updated the Covered Material Category (CMC) list to include recycling rates, and withdrawn earlier regulations in favor of revised draft rules issued in late January 2026.
Statutory deadlines in SB 54 remain unchanged, so producers of packaging and paper should treat 2026 as a critical preparation year for California reporting and source reduction reporting/planning. As of February 2026, details below reflect the status at the time of CAA’s February 19 webinar and current CalRecycle publications.
Latest California SB 54 and CAA Program Milestones
SB 54 (Plastic Pollution Prevention and Packaging Producer Responsibility Act) creates California’s largest EPR program, covering thousands of producers of single-use packaging and single-use plastic food service ware. CalRecycle’s Material Characterization Study provides baseline data on the types and quantities of covered materials in California’s waste stream and will inform recycling rate calculations, fee structures, and performance targets.
CalRecycle has also updated the Covered Material Category list as required annually and has added recycling rates to each CMC, covering material classes such as plastic, glass, metal, paper and fiber, and wood/other organics. This makes the CMC list the primary reference for how packaging and paper must be categorized for California EPR reporting.
At the same time, producers face uncertainty around final SB 54 regulatory language and timelines because CalRecycle withdrew earlier draft regulations in January 2026 and released revised proposals with a short public comment window.
CAA has been approved as the first Producer Responsibility Organization (PRO) for SB 54 and is now preparing a California program plan. According to CAA’s February update, the organization is working toward submitting this program plan to the Producer Responsibility Advisory Board by June 15, 2026, followed by a 60‑day public comment period expected from June 15 to August 13, 2026 under current draft regulations.
Producers should plan to review and comment on this plan, coordinating cross‑functional input from sustainability, packaging, legal, and finance teams to reflect operational realities.
Who and What Are in Scope in California’s Packaging EPR
SB 54 regulates “covered materials,” which include single-use packaging and single-use plastic food service ware sold, offered for sale, distributed, or imported into California. CalRecycle’s CMC list groups these materials by class and format and now links each category to an estimated recycling rate.
Many producers are already seeing difficulty interpreting Covered Material Category recycling rates for complex packaging, especially multi-material items where different components map to different CMCs. RLG experts can advise and support with this.
“Producers” under SB 54 include companies that place covered material on the California market, such as brand owners and in some cases importers or private label entities. This can create challenges mapping producer obligations across brand owners, importers, and private label relationships where contracts and brand control differ.
CAA, as the PRO, will enroll producers, manage reporting channels, and help fund system improvements, but producers remain responsible for accurate registration and data. Aligning internal systems with CAA registration and reporting formats is therefore becoming a practical priority for affected manufacturers and retailers.
2026 Reporting Timeline and Emerging Producer Challenges
CAA’s February 2026 communication outlines a draft 2026 California report schedule, based on current draft regulations and subject to change:
- Baseline Producer Report using calendar year (CY) 2023 data, with a CAA report date of November 15, 2025.
- Annual Supply Report using CY 2025 data, covering 2026 early fees and 2027 program fees, due May 31, 2026.
- Annual Source Reduction Report using CY 2025 data, also due May 31, 2026.
- Individual Source Reduction Plan timing remains to be determined, but planning expectations are already emerging.
Read more here for a list of EPR deadlines in the United States.
Once final regulations are effective, producers will have 30 days to confirm their November 2025 baseline report or submit a baseline producer report if they have not already done so. This creates short preparation time to validate or submit baseline producer reports after regulations take effect, especially for companies that have not yet consolidated packaging and paper data for California.
How RLG Can Help
RLG offers EPR compliance support services that can be end-to-end for robust and sophisticated solutions, to a la carte solutions for small teams.
With over 66 million SKUs of packaging data, RLG’s database is unrivalled for validating packaging data and plugging gaps. Meanwhile, our experts offer tailored guidance that helps businesses create actionable EPR compliance strategies.
Reach out now to schedule a free, confidential, fifteen-minute discovery call.
Editor’s note: This article has been reviewed by EPR compliance expert Kristen Kelly.
Disclaimer: This content is for informational purposes only and should not be considered legal advice. Laws are subject to interpretation and change without notice, so always consult with professional advisors and refer to primary sources. Content is acknowledged by RLG as accurate as of publication date but may not be regularly updated.
