This is an important reminder regarding upcoming SB 54 deadlines and available resources for growers, packers, shippers, and brand owners using plastic packaging in California.
Important Deadline
June 1, 2026 – Deadline to register as a Producer under SB 54.
If you are going to file for an Exclusion or an Exemption, we recommend you still register as a Producer in the event an Exclusion is ultimately denied avoiding any penalties for late registration. The Exclusion Notice can be submitted at any time.
Producer Reminder
You generally do NOT have to register as a Producer for covered material used during harvest and field packing.
Western Growers strongly encourages members to add a statement on invoices to customers such as:
“This produce was harvested and packaged in the field” to document the product has been field packed.
However, if covered material is added later in the warehouse before shipment, you MAY be considered the Producer for that packaging material and may need to register.
Exclusion Notices to CalRecycle
An Exclusion Notice may be submitted to CalRecycle at any time for packaging necessary to comply with federal food safety rules, regulations, and guidelines where no feasible recyclable or compostable alternative currently exists.
Important Guidance Documents to Be Submitted with Exclusion
Western Growers has developed guidance documents, templates, and supporting citations specifically for fresh-cut produce packaging to help members complete and support an SB 54 Exclusion Notice submission to CalRecycle.
Western Growers strongly recommends that members upload the WG guidance documents and supporting materials as supplemental information with their Exclusion Notice submission.
CalRecycle has confirmed that supporting guidance documents, best practices, industry recommendations, academic research, and technical information are relevant to the exclusion process because they help demonstrate:
- Why the packaging is necessary for food safety;
- How the packaging complies with federal food safety standards; and
- Why feasible recyclable or compostable alternatives may not currently exist.
Resources Available on the Western Growers Website
All SB 54 resources are available at the top of the Western Growers homepage under:
“SB 54 Plastic Packaging Resources and Updates”
Resources include:
- Producer guidance
- Supporting food safety justifications
- Federal rules, regulations and guidelines
- Filing instructions
- CalRecycle guidance documents
- Exemption information
- Regulatory updates
Please contact Gail Delihant [email protected] or Jeana Cadby [email protected] with any questions regarding Producer status, Exclusion Notices, or Exemption applications.
DISCLAIMER: This email does not provide legal advice. Although this message may contain information and advice that may affect possible legal matters, it cannot and should not constitute or substitute legal advice. If you have further questions or need legal advice, please contact a lawyer.