Materials covered
- All single-use packaging (rigid plastic, flexible plastic, glass, metal, paper/fiber)
- Plastic single-use food service ware
- Cosmetic primary packaging, secondary packaging, and shipping materials
Packaging EPRCA
California packaging producer responsibility
SB 54 — Plastic Pollution Prevention and Packaging Producer Responsibility Act (2022); CalRecycle regulations effective May 1, 2026
California's Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54, 2022) requires producers of single-use packaging and plastic food service ware sold in California to join a Producer Responsibility Organization; Circular Action Alliance is the approved PRO. CalRecycle's SB 54 regulations took effect May 1, 2026, and producers' first annual supply report, on calendar-year 2025 data, was due to CAA on May 31, 2026. By 2032 the law requires a 25% cut in single-use plastic, a 65% recycling rate for single-use plastic, and all single-use packaging to be recyclable or compostable.
Last updated:
- Producer Responsibility Organization
- Circular Action Alliance (CAA)
Who is a producer in California?
Generally the brand owner whose name appears on the packaging, or the importer of record when the brand is not in California. Small producers below the law's revenue threshold are exempt; check the current threshold with CalRecycle.
Producer obligations
- Join Circular Action Alliance, the approved PRO
- Report supply data (packaging weight by material category) to CAA every year; the first annual supply report, on calendar-year 2025 data, was due May 31, 2026
- Report on source reduction: a 2023 baseline producer report (due May 31, 2026) and an individual source reduction plan (due August 1, 2026)
- Pay CAA's fees: early fees are invoiced in one installment in August 2026, and program fees follow CalRecycle's approval of CAA's program plan
- Meet the 2032 targets: 25% less single-use plastic, a 65% recycling rate for single-use plastic, and 100% of single-use packaging recyclable or compostable
Compliance timeline
- Active
CAA approved as PRO
CalRecycle approved Circular Action Alliance as the first Producer Responsibility Organization under SB 54.
- Active
Regulations take effect
CalRecycle's permanent SB 54 regulations were approved by the Office of Administrative Law and took effect the same day.
- Reporting begins
First annual supply report
Producers' annual supply report to CAA on calendar-year 2025 data, and the 2023 baseline producer report for source reduction.
- Reporting begins
Individual source reduction plan
Producers' individual source reduction plans were due to CAA.
- Fees begin
Early fees invoiced
CAA invoices California early fees, based on the 2025 supply data, in one installment.
- Upcoming
Program plan approved; program begins
CalRecycle approves CAA's program plan (CAA submitted it June 15, 2026) and the program begins.
- Upcoming
2032 targets
25% source reduction of single-use plastic, a 65% recycling rate for single-use plastic, and 100% of single-use packaging recyclable or compostable.
How Cosmetica helps
Cosmetica coverage for California
Cosmetica builds California's three CAA filing workbooks (the annual supply report, the annual source reduction report and the individual source reduction plan) from your packaging BOMs and per-state sales, and marks every packaging weight that is an estimate. It does not calculate fees.
Primary sources
- CalRecycle SB 54 program page
- CalRecycle SB 54 regulations
- Full text of SB 54
- Circular Action Alliance — California
- Circular Action Alliance — 2026 producer reporting
EPR statutes and rules are evolving. Verify the latest dates, fee schedules, and de minimis thresholds with the state agency before relying on this summary for compliance decisions.