Packaging Regulation in CA SB 54 approved by the California Office of Administrative Law (OAL) with early effective date; Obligated companies must register with the Circular Action Alliance (CAA) by June 1 to avoid penalties
As of May 1, 2026, the California Department of Resources Recycling and Recovery (CalRecycle) officially approved and implemented the permanent regulations for the Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54). The registration deadline for Producers has been updated to June 1, 2026.
This accelerates the compliance timeline for companies that sell, distribute or import covered materials into and within California.
Under SB 54, producers of single‑use packaging and plastic single‑use food service ware must participate in a statewide EPR system. The law shifts end‑of‑life management costs from consumers and local governments to the companies that place these materials into the California market. The program requires producers to join a Producer Responsibility Organization (PRO), and the state has designated the Circular Action Alliance (CAA) as the PRO responsible for administering the system.
The Packaging Extended Producer Responsibility System (PEPRS) is designed to support producer registration, reporting, document submittals and compliance monitoring.
To assist entities with transitioning into program implementation, CalRecycle published a new webpage for Producers, and plans to publish new guidance materials soon.
Mandatory Registration: 30 Days to Act
All obligated producers must now register with the CAA by June 1. Failure to do so could result in enforcement actions and penalties. This update does not constitute legal advice.
- CAA California Overview: https://circularactionalliance.org/california
- Producer Registration Page: https://circularactionalliance.org/registration
- Registration Portal: https://www.circularactionportal.org/producers/s/producer-registration
CAA is responsible for submitting lists of registered producers to state agencies under multiple EPR laws. Producers who do not register risk being excluded from compliance support, data reporting guidance and other required program functions.
If you have any questions, please contact [email protected].
LEARN MORE
Navigating EPR in the U.S.: Deadlines, Reporting, and the Fresh Produce Focus Town Hall
Date: Wednesday, May 13, 2026
Time: 11:00 a.m. to 12:00 p.m. PT
Format: Virtual
Register here.
*This event is exclusive to members of Western Growers.