We wanted to share a brief update following a recent meeting between California Department of Food and Agriculture (CDFA) Secretary Karen Ross, CalRecycle Director Zoe Heller and CalRecycle staff to address several questions related to California’s SB 54 implementation.
Key Takeaways
Source Reduction Plans Due Aug. 1, 2026
- The source reduction submittal is intended to help Circular Action Alliance (CAA) establish a baseline and better understand what it will take to achieve future reduction targets.
- These are targets.
- If a producer has already reduced covered materials as much as reasonably possible, their plan can simply state that no further reductions are planned because all feasible reductions have already been achieved.
- Reduction performance will be measured across the entire producer community rather than on an individual company basis. The expectation is that companies able to make greater reductions may help offset those that have limited opportunities for additional reductions.
Exemptions
- Exemptions may be granted for up to five years and potentially longer, depending on a producer’s efforts to comply or if compliance could create health and safety concerns.
Wooden Pallets
- As a result of our request, CalRecycle has decided wooden pallets are not considered covered material.
CAA Plan and Public Comments
The SB 54 Advisory Board will meet on June 26, 2026, to discuss CAA’s Plan.
- Time: 10:00 a.m. – 4:00 p.m. PST
- Location: CalEPA Headquarters, Sierra Hearing Room (2nd Floor)
1001 I Street, Sacramento, CA 95814 - Participation: In person, Zoom Webcast
Public comments on the Plan are due Aug. 1, 2026.
Binding Contracts and Compliance
- CalRecycle and CAA indicated they do not intend to immediately enforce binding contract requirements through penalties.
- Their current approach is to work with producers to help bring them into compliance before pursuing enforcement actions.
Exclusion Requests
- CalRecycle and CAA are continuing to review our exclusion documentation with legal counsel.
- They will let us know if additional information is needed.
- Importantly, exclusions will be considered for an entire category of covered material rather than only on a company-by-company basis.
Delinquency Notices from CAA
Several members have raised concerns regarding delinquency notices received from CAA. We received a response from CAA stating they were working to improve its registration process and to reduce unnecessary automated notices. They intend to correct the automated responses that have caused confusion.