California Program Plan Public Comment Period
June 15 - Aug. 14, 2026
On June 15, Circular Action Alliance California submitted its program plan to the SB 54 Producer Responsibility Advisory Board, an important milestone in implementing SB 54. The plan is now available for public comment, providing an opportunity for interest holders to share input and help strengthen the final program plan. Learn more in our press release.
About the California Program Plan
Developed to meet the requirements of SB 54 and regulations, the California program plan outlines how the statewide recycling and reuse system will be supported, including approaches to funding, material management, reporting and system performance. As the approved nonprofit Producer Responsibility Organization (PRO), Circular Action Alliance is responsible for developing and implementing a program that meets the SB 54 requirements under CalRecycle oversight.
The plan is grounded in data-driven analysis, reflecting extensive technical work and collaboration across California’s recycling and reuse system. It draws on ongoing engagement with local governments, service providers, producers and communities, as well as a series of public consultation sessions in fall 2025 focused on key program elements.
Together, this work provides a clear, informed foundation for implementing SB 54 in a way that is operationally feasible.
Update (June 18, 2026): Correction to fee schedule table in Chapter 9 – Fee Setting
An inconsistency in the fee schedule table found on pages 297-307 of Chapter 9 - Fee Setting has been corrected. Revised files are available below. The California illustrative fee schedule posted to CAA’s website on May 1 remains accurate and unchanged.
Download by Chapter
Participate in the Public Comment Period
The public comment period is an important opportunity for interest holders to review the program plan and provide feedback to help inform its final development.
We encourage input that is:
Specific and actionable
Focused on particular sections or chapters of the plan
Oriented toward improving clarity, feasibility, or implementation.
Balanced: in addition to what you'd like to see changed, please also tell us what you support in the plan, so we know what’s working.
Feedback submitted during this period will be reviewed, considered and summarized as Circular Action Alliance prepares the final program plan for submission to CalRecycle in October 2026.
To submit comments:
Fill out each of the required elements on the comment form.
Submit your comments one at a time by chapter and associated page number(s).
NOTE: Given the limited timeframe to incorporate comments into the final Program Plan, CAA encourages commenters to both identify concerns and propose concrete resolutions.
Public Webinar: SB 54 Program Plan Overview
On July 8, 2026 at 1:00 p.m. PT, CAA hosted a public informational webinar to introduce the program plan, outline key elements and explain how to participate in the public comment process.
During the webinar, participants:
Received a high-level overview of the program plan, including key elements such as funding, material management and system operations
Learned how the plan was developed, including the role of data analysis and interest holder engagement
Learned how to participate in the public comment period and what types of input are most helpful
This session was designed to support transparency and ensure interest holders have the information needed to review the program plan and provide meaningful feedback.
Frequently Asked Questions (FAQ)
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The California program plan is a comprehensive, data-driven roadmap developed by Circular Action Alliance to implement SB 54 requirements, outlining how the state will reduce packaging waste and strengthen recycling and reuse systems.
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Circular Action Alliance is the nonprofit Producer Responsibility Organization named by CalRecycle to develop and implement SB 54.
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No. As the nonprofit Producer Responsibility Organization appointed by CalRecycle, CAA’s role is to develop and implement the program plan to meet the requirements of SB 54, not to set or change policy.
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The plan is grounded in extensive technical analysis and shaped by extensive collaboration with producers, local governments and system participants, incorporating thousands of comments and insights from across the recycling and reuse system.
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The program plan is designed to meet statutory and regulatory requirements as written, aligning directly with the framework established by SB 54 and CalRecycle oversight.
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CAA’s focus is translating complex policy into a program that can deliver in real-world conditions across California’s diverse and highly complex recycling and reuse system.
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With submission, the plan enters a formal public comment period—an important step that offers the opportunity for input to help strengthen the program before finalization.
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All interest holders (including producers, local governments, industry participants and community members) are encouraged to provide input during the formal comment period.
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CAA will review and incorporate relevant feedback to strengthen the program plan and support a more effective, implementable system as it moves toward finalization.
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Implementation requires coordination across a large, diverse system with varying local conditions, and the plan is structured to reflect and work within that complexity.
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The plan is built on broad engagement across California’s recycling and reuse system and is designed to enable flexible participation, recognizing that successful implementation depends on coordinated action from thousands of interest holders statewide.
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Implementing a law of this scale and complexity requires a phased, practical approach focused on making measurable progress in real-world conditions rather than an immediate, statewide transition.