California's packaging EPR law is SB 54, the Plastic Pollution Prevention and Packaging Producer Responsibility Act of 2022, administered by CalRecycle. Producers of single-use packaging and plastic single-use foodware sold in California must join a producer responsibility organization, the Circular Action Alliance being the sole approved one, and meet escalating targets: by 2032 all covered material must be recyclable or compostable, the recycling rate for plastic covered material must reach 65 percent, and plastic covered material must be cut 25 percent by source reduction. The permanent regulations took effect May 1, 2026; producer registration closed June 1, 2026, and the first annual reports covering 2025 data were due May 31, 2026. Civil penalties can reach $50,000 per day per violation.
California's packaging EPR law is SB 54, the Plastic Pollution Prevention and Packaging Producer Responsibility Act of 2022, administered by CalRecycle. It pairs the producer responsibility structure with recycling and source-reduction targets, and CalRecycle estimates several thousand producers are in scope. This guide covers what SB 54 requires, who is obligated, the deadlines, the targets, fees, and penalties.
The law and the administrator
SB 54, the Plastic Pollution Prevention and Packaging Producer Responsibility Act, was enacted in 2022 and is implemented by CalRecycle through permanent regulations approved by the Office of Administrative Law on May 1, 2026, effective the same day. It covers single-use packaging and plastic single-use foodware offered for sale, distributed, or imported into California. Like the other PRO-model states, it runs through a producer responsibility organization, and the Circular Action Alliance is California's sole approved PRO.
Who is an obligated producer
SB 54 defines the producer through a hierarchy that generally lands on the brand owner of the covered material. Where there is no brand owner with a California presence, the obligation moves to the importer or distributor. Because CalRecycle estimates thousands of producers in scope, many companies that did not think of themselves as packaging producers are covered.
Exemptions and covered material
A producer with less than $1 million in gross sales in California in the most recent calendar year qualifies for the small-producer exemption (PRC § 42060(a)(5)(A)), but it must still register with CalRecycle and apply for the exemption rather than simply ignore the program. Covered material is broad: single-use packaging and single-use plastic food-service ware, sorted into the state's covered-material categories of glass, ceramic, metal, paper and fiber, plastic, and wood and other organics. Packaging is defined functionally, as the separable, distinct material component used to contain, protect, handle, deliver, or present a product, which sweeps in sales packaging, transport packaging, and e-commerce packaging.
The 2026 deadlines
Two dates anchored 2026, and both have passed. Producer registration ran on a 30-day window from the May 1, 2026 effective date of the permanent regulations, closing June 1, 2026; by that date a producer had to register with the Circular Action Alliance, register with CalRecycle as an independent producer, or register and substantiate the small-producer exemption. Separately, the 2026 California Producer Report and the Annual Source Reduction Report, each covering 2025 data, were due by May 31, 2026 (recognized June 1 because May 31 fell on a Sunday), the first of an annual reporting cycle; producers registering with the PRO also submitted 2023 baseline supply data. A producer that is in scope but has not registered or reported is out of compliance.
The targets
SB 54 is not only a fee program; it sets outcomes the system must hit. By January 1, 2032, all covered material must be recyclable in the state or eligible to be labeled compostable (PRC § 42050(b)), the recycling rate for plastic covered material must reach 65 percent, on interim steps of 30 percent by 2028 and 40 percent by 2030 (PRC § 42050(c)), and the use of plastic covered material must fall 25 percent through source reduction (PRC § 42057(a)). These targets shape the eco-modulated fees, because hard-to-recycle plastic is both penalized on fees and squeezed by the source-reduction mandate.
Fees and penalties
Fees are set by the PRO based on the tonnage of each covered material a producer reports, eco-modulated so more recyclable material pays a lower rate. A producer found non-compliant can face administrative civil penalties of up to $50,000 per day per violation (PRC § 42081(a); $25,000 per day for qualifying small entities), assessed only after 30 days' notice and an opportunity for a corrective action plan.
For the multistate picture, see the US packaging EPR compliance guide; to determine obligated-producer status, see the US packaging EPR producer obligation assessment.
Primary sources
- California SB 54 (2022), the Plastic Pollution Prevention and Packaging Producer Responsibility Act: California's packaging EPR law (Public Resources Code 42040 et seq.), administered by CalRecycle.
- Circular Action Alliance: The producer responsibility organization designated or selected to run the program in most US packaging EPR states; producers register, report, and pay fees through it.