What is SB 54 and Why It Matters

California’s Plastic Pollution Prevention and Packaging Responsibility Act (SB 54) was signed into law in June 2022 and establishes an ambitious Extended Producer Responsibility (EPR) framework for packaging and plastic food service ware in the United States. It shifts the burden of management and design from municipalities to producers, with the objective of achieving measurable reductions by 2032.

As the world’s fifth-largest economy, California often sets the standard for national brands. SB 54 is already compelling companies to redesign packaging and upgrade data systems to remain eligible for the California market. Because regulations and buyer expectations in other states tend to follow California’s lead, preparing now helps companies reduce future compliance and market-access risks.

In this two-part series, this post delivers a high-level status update, covering what SB 54 is, what has changed in 2025, and where the rulemaking stands today. The next installment will dive into covered materials, fee mechanics, and practical examples.

Key Takeaways

1. SB 54 establishes binding 2032 goals for recyclable packaging, source reduction and recycling rates

2. The governor pressed pause on the first draft of rules earlier this year, which slowed things down, but CalRecycle has restarted the rulemaking with updated drafts and a new comment process.

3. The official rulemaking portal for SB 54 is maintained by CalRecycle, which serves as the primary source for draft texts, comment periods, and stakeholder workshops. 

   
   

What is SB54?  

SB 54 is California’s landmark packaging EPR law that shifts both the cost and operational responsibility for managing packaging waste from local governments to producers, typically the brand owner, or if none exists, the importer or distributor. Under the law, producers must fund and coordinate statewide recycling system improvements through the Circular Action Alliance (CAA).

The law applies to all packaging and plastic food-service ware sold in California. CalRecycle maintains the official Covered Material Categories list, which defines that materials fall under SB 54 for reporting, fee setting, and future design criteria. We explore these categories in more detail in the second post.

Producers must join a CalRecycle-approved Producer Responsibility Organization (PRO) or be represented by one. The PRO develops the statewide program plan, administers producer fees, funds collection/sorting/recycling upgrades, and reports progress to the state.

Policy goals and key provisions

Producers rather than municipalities are responsible for waste reduction, recycling and reuse outcomes. SB 54 labels clear goals to be met by 2032:

• 100% of single-use packaging and food service ware sold are recyclable or compostable

• 65% of one time use plastic packaging  and food service ware is recycled

• 25% reduction in sale/distribution of one-time use plastic packaging and food service ware

Also, expanded polystyrene (EPS) requirement:

• To continue selling EPS food service ware in California, producers must show a 25% recycling rate by January 1, 2025. That target has not been met, so EPS food service ware such as single-use cups and takeout containers may not be sold, offered for sale, distributed, or imported in or into the state.

  
  

Funding from Fees

Producer fees fund the program’s “covered costs,” which include reimbursements to local jurisdictions for the collection, transportation, and processing of covered materials, along with related program administration and contamination reduction efforts. 

Starting in 2027, producers must pay an annual surcharge totaling $500 million per year (through 2036) under SB 54. These funds are collected via the approved PRO and collected by the California Department of Tax and Fee Administration (CDTFA). The funds are then appropriated by the state to support agencies in mitigating plastic‐pollution impacts, especially in frontline, environmental-justice communities.

What Changed in 2025

In March 2025, Governor Gavin Newsom declined to approve CalRecycle’s initial draft rules, citing concerns about cost burdens and fairness for businesses. This intervention effectively slowed implementation, requiring CalRecycle to restart the rulemaking process and publish a revised draft in May 2025. For companies, this means the transition period remains open and the rules are not yet final, although the statute’s binding 2032 timelines remain unchanged.

Where the Rules Live and How They Are Finalized

All draft regulations, notices, as well as workshops for SB 54 are published on CalRecycle’s official rulemaking site. Key resources include the draft regulation text PDF, which includes provisions on producer registration, data reporting, and fee frameworks. When the formal package is adopted, CalRecycle will submit to the Office of Administrative Law (OAL), trigger the 45-day comment period (start on August 22, 2025 and end on October 7, 2025), and then finalize it to ultimately publish.

Near-Term Dates 

1. File your 2023 supply report by November 15, 2025. The deadline is mandatory, and producer registration deadline was September 5, 2025 (if you missed it, register immediately and still file). 

2. Expect additional guidance throughout 2026: Cal Recycle and CAA are expected to release further clarifications next year. Use 2026 to strengthen data quality, confirm covered materials, map covered SKUs and begin planning for budgets. 

3. Producer fees will begin Jan 1, 2027: CAA’s current timeline places the start of fee assessment in 2027, following completion of the rulemaking and PRO planning processes. 

   
   

Actions to Take

1. Stay subscribed to CalRecycle’s Updates to receive notices of comment windows and workshops

2. Review whether your packaging or food service ware falls within “covered materials” (see CalRecycle’s Covered Material Categories List).

3. Begin gathering data, determine your volume of packaging sold in California, assess material types, and evaluate design compliance (recyclability, compostability, reuse options)

4. Monitor the regulatory timeline closely: while the statute’s 2032 deadlines remain fixed, key implementation steps, such as PRO registration, plan submission, and fee schedules, are still moving through the rulemaking process.

This first post provides a foundational overview of SB 54: what it is, why it matters, what changed in 2025, and where to track the rule-making. In the next post, we’ll move into the covered material categories, how the fee-impact model is shaping up, and steps that brands can begin taking now.