CalRecycle has released its proposed permanent regulations under the SB 54 Plastic Pollution Prevention and Packaging Producer Responsibility Act. The 166-page document will have varying impacts on businesses depending on their business model.
What Members Need to Know
Each business should have its legal team review the regulations to determine whether to register under the program.
If you submitted comments on prior versions, you must resubmit them on this version for them to be considered.
There is categorical exclusion language included in the regulations, located in Article 2, Section 18980.2 (pages 19-20). This section provides a framework for requesting exemptions when compliance would be feasible due to technical, legal or other constraints. WG strongly encourages members to support this language in their comments.
Here are some key dates members should be aware of:
Written comment deadline:
Oct. 7, 2025
Public Hearing:
Date: Oct. 7, 2025 at 10 a.m. PST
Location: CalRecycle Headquarters, Byron Sher Auditorium, 1001 I Street, 2nd floor, Sacramento, CA
Cost: Free
Virtual Participation: Available via Zoom – Register here.
Webcast Viewing: Available through the Public Meeting Live Webcasts
How to Submit Written Comments
The written comment period permits any interested person, or their authorized representative, to submit written comments addressing the proposed amendments to CalRecycle. Written comments, which offer a recommendation and/or objection, or support the proposed regulations, should indicate the section to which the comment or comments are directed. CalRecycle will only consider written comments sent to CalRecycle and received during the written comment period, which begins on Aug. 22, 2025, and ends on Oct. 7, 2025. Written comments received by CalRecycle after the close of the public comment period are considered untimely. CalRecycle may, but is not required to, respond to untimely comments, including those raising significant environmental issues. Comments submitted in writing must be addressed to one of the following:
Postal mail:
Csilla Richmond
SB 54 Plastic Pollution Prevention and Packaging Producer Responsibility Act Permanent Regulations
Department of Resources Recycling and Recovery, Regulations Unit
1001 “I” St., MS-24B, Sacramento, CA 95814
Electronic submittal:
SB 54 Plastic Pollution Prevention and Packaging Producer Responsibility Act 45-Day Comment Period
For full details and access to the proposed regulations, visit: CalRecycle Packaging EPR.
If you have additional questions, WG members can contact Gail Delihant, Senior Director of CA Government Affairs, at [email protected].