CalRecycle Withdraws Proposed SB 54 Regulations: What California Packaging Producers Need to Know
On January 9, 2026, CalRecycle withdrew its proposed SB 54 regulations from the Office of Administrative Law’s review, signaling another delay in the state’s landmark packaging EPR rollout. The agency says it plans to work on its revisions to improve clarity, primarily around food and agricultural packaging, and will reopen a 15-day public comment period, but statutory deadlines will remain the same. The date for the 15-day public comment period has not been confirmed yet.
For producers who expected finalized rules on January 9, this is a curveball in the rulemaking process marked by multiple resets since Governor Newsom’s March 2025 directive to restart regulations.
Why CalRecycle Pulled the Proposed Regulations
CalRecycle stated that the withdrawal allows for revisions that will “improve clarity and help implement the law” while “minimizing costs for small businesses and working families.” The focus, according to the agency, is on food and agricultural packaging provisions.
What Products and Materials Are Affected Under SB 54
SB 54 covers single-use packaging and single-use plastic food service ware sold or distributed in California. By 2032, the law requires:
- 100% of covered materials to be recyclable or compostable.
- 65% recycling rate for single-use plastic packaging and food service ware.
- 25% source reduction compared to 2023 baselines.
While the exact scope of exemptions for food and agricultural packaging remains in flux, producers of consumer goods, food products, and beverage packaging should prepare that their materials may be in scope until final rules confirm otherwise.
Who Is Affected: Defining “Producers” Under California EPR
Under SB 54, “producers” include brand owners, importers, and—in some cases—retailers or marketplace facilitators that introduce covered packaging into the California market.
Producers that registered with Circular Action Alliance (CAA), the designated PRO for California packaging EPR, and submitted 2023 baseline data in November 2025, are directly affected by the delayed resubmission timeline.
This also affects producers who did not submit by this deadline as well; the 2023 data report is a statutory requirement, so even if the deadline is pushed back, postponing preparations will make it more and more difficult to collect required data and it’s a tight turnaround of 30 days once the regulations are finalized.
What California Producers Should Do Now
- Don’t assume the job is done. Even if baseline data was submitted in 2025, producers must resubmit or confirm their 2023 data within 30 days of final rule adoption. The resubmission window remains undefined until regulations are finalized.
- Keep 2023 data accessible and well-documented.Build internal ownership across sustainability, packaging, and finance teams so any required adjustments to material definitions, categorizations, or thresholds can be made quickly.
- Monitor CalRecycle’s rulemaking page. Watch for announcements on the new 15-day comment period, when more detail on timing and scope is expected.
- Stay engaged with CAA. The PRO is continuing work on its program plan for submission by June 2026. Producers who have not yet signed a Participant Producer Agreement should consider doing so to stay informed. RLG can advise on best practices for joining a PRO.
- Consider Horizon Scanning support. Tracking repeated regulatory pivots drains internal resources. Maintaining vigilant watch of legislation, or having RLG do it for you with Horizon Scanning, ensures you’re never caught off guard by shifting deadlines.
How Producers May be Affected
Producers are grappling with concrete challenges as SB 54’s rulemaking continues to shift:
- Uncertainty over whether existing 2023 data meets revised definitions once regulations are final. (If you’re unsure, RLG can collect, format, and even validate packaging data).
- Inability to close out compliance planning when the resubmission deadline is undefined.
- Lack of visibility into how food and agricultural exclusions may, or may not, apply to specific SKUs.
- Resource drain from repeated regulatory pivots since March 2025.
- Risk of building compliance systems that require redesign after final rules are issued.
- Pressure to participate in the comment period while simultaneously preparing data and systems for a 2027 launch.
These are not abstract regulatory headaches—they translate directly into budget overruns, compliance gaps, and leadership frustration.
“Repeated resets are exhausting for compliance teams, but they also create opportunity,” said Kristen Kelly, Environmental Compliance Coordinator at RLG. “Producers who use this window to clean up their packaging data and document ownership across teams will be far better positioned when the 30-day clock finally starts. Don’t let the uncertainty become an excuse for inaction, but treat it as extra prep time.”
How RLG Supports California Packaging Compliance
RLG offers end-to-end support for producers navigating California’s packaging EPR landscape:
- Horizon Scanning: Continuous monitoring of regulatory developments so producers are never blindsided by shifting timelines or new comment periods.
- EPR Assessments: Gap analyses that identify where your current compliance posture falls short of emerging requirements.
- Packaging Data Health: Data collection, validation, and analysis backed by a database of over 60 million SKUs—critical for accurate baseline reporting and fast resubmission.
- Environmental Compliance Management: Ongoing support to translate regulatory requirements into practical internal processes.
For producers facing undefined timelines, fragmented internal data, and the prospect of yet another round of public comment, RLG provides the expertise and bandwidth to keep compliance on track.
Next Steps for Producers Selling Products in California
CalRecycle has not announced when the new 15-day comment period will open. Producers should monitor the situation for updates, or work with a compliance team like the people at RLG. CAA’s June 2026 program plan deadline remains unchanged, and the program is still expected to launch January 1, 2027.
Book a confidential, fifteen-minute discovery call with RLG to review your California packaging exposure, assess your data readiness, and build a compliance roadmap that accounts for regulatory uncertainty.
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 accurate as of publication date but may not be regularly updated.
Authorship: This article was reviewed, on January 13, 2026, by RLG’s EPR compliance expert Kristen Kelly.
