California
California’s Plastic Pollution Prevention and Packaging Producer Responsibility Act requires producers of residential and commercial single-use packaging and plastic single-use food service ware to join a Producer Responsibility Organization (PRO), and through the PRO, fund the end of life of those materials, which includes processing and recycling. Additionally, the PRO must remit to the state $500 million each year, starting in 2027 and ending in 2037 to be placed in the California Plastic Pollution Mitigation Fund.
On January 8, 2024, CAA was selected by CalReycle as the state’s inaugural, single PRO.
FAQ
Key Information for Producers
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On January 8, 2024, CAA was selected by CalReycle as the state’s inaugural, single PRO.
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To comply with producer registration requirements under California, Colorado, and Oregon EPR laws for paper and packaging products, covered producers must register with CAA unless the producer qualifies for an exemption or the producer intends to submit an individual compliance plan, under applicable law.
Regulations in Colorado required producers to register by October 1, 2024. Producers who did not register by that date may be subject to enforcement. CAA will be submitting a list of registered producers to the Colorado Department of Public Health & Environment following the October deadline. CAA will be submitting a list of registered producers to the Colorado Department of Public Health & Environment as required.
CAA was required to provide the Oregon DEQ with a list of registered producers as part of CAA’s revised program plan, submitted on September 27, 2024.
Producers in these states who missed the deadline need to still register with CAA.
Only registered producers will gain access to CAA’s producer education forums, such as the Producer Working Group (PWG), and receive detailed guidance to support data preparation and reporting.
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California, Colorado, Maine, and Oregon EPR laws have different fee collection requirements and timelines. Oregon will be the first state where producers have fee obligations when the program begins on July 1, 2025. Fee obligations in Colorado will begin in January 2026. In California, fee obligations start in January 2027.
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CAA has set a preliminary reporting deadline in California of August 31, 2025.
Each state will have specific reporting categories for all materials in scope of the program, whether or not they are determined to be recyclable. Producers will report the type and weight of their covered materials into these categories.
Producers can expect detailed guidance on reporting to be released in late-October 2024. Only registered producers who have a signed a Participant Producer Agreement (PPA) with CAA will be able to access the reporting guidance. The PPA outlines the terms and conditions between producers and CAA and will be available to registered producers in late-October.
CalRecycle may develop rules to clarify the date by which producers must report information to the PRO, and CAA will develop guidance to support producers with packaging data reporting.
Key Milestones in the Regulatory and Implementation Process
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June 30, 2022
Governor Newsom Signs SB 54.
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July 1, 2023
CalRecycle Makes Advisory Board Appointments.
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September 2023
CalRecycle Releases PRO Application.
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January 1, 2024
PRO Application Deadline.
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January 8, 2024
CalRecycle Selects CAA as the inaugural, single PRO.
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On or Before July 1, 2024
CalRecycle must publish a list of covered material categories.
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January 1, 2025
Deadline for producers of expanded polystyrene food service ware to demonstrate 25% recycling rate to CalRecycle.
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August 2025
CAA Preliminary Deadline for Data Reporting.
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Expected Mid-2026
PRO Submits Plan.
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Expected Mid-2026
SB 54 Advisory Board Reviews Plan and Offers Written Comments.
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On or Before Jan 1, 2027
CalRecycle Approves Plan, Program Begins.
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March 1, 2027
PRO Remits First California Plastic Pollution Mitigation Fund Fees.
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July 1, 2027
PRO Remits First Administrative Fees to CalRecycle.
Updates
Informal Rulemaking
CalRecycle hosted monthly stakeholder workshops from March to July 2023 as part of an informal rulemaking process. Discussion documents and presentation slides from each stakeholder workshop are found on CalRecycle’s SB 54 landing Page.
On December 28, 2023, CalRecycle released proposed draft regulatory text. In addition, it released the following documents: Covered Material Categories List, Covered Materials Categories Supplemental Material, and SB54 Report to the Legislature.
CalRecycle released its initial SB 343 (Truth in Labeling) determinations on what can be potentially labeled as recyclable and compostable in California. SB 54 requires CalRecycle to use criteria established by SB 343 to evaluate the potential recyclability and compostability of covered material categories. Formal public hearings will be held in the Spring. Track the rulemaking process, including information on how to comment, on CalRecycle’s Accurate Recycling Labels page.
Formal Rulemaking
CalRecycle opened the public comment period for SB 54 on March 8. CalRecycle held a public hearing on April 23. CAA submitted comments on May 8, 2024. CalRecycle has until January 1, 2025, to promulgate the rules. Please refer to CalRecycle’s Plastic Pollution Prevention and Packaging Producer Responsibility Act Permanent Regulations page for additional details included proposed regulation text and related documents.
Compliance Update
On September 11, CalRecycle provided notification on the upcoming SB 54 deadline concerning expanded polystyrene food service ware. Prior to January 1, 2025, producers of expanded polystyrene food service ware must demonstrate to CalRecycle a recycling rate of not less than 25% of all expanded polystyrene food service ware sold into California. If this demonstration is not adequately made, expanded polystyrene food service ware will be prohibited from sale, offering, distribution or importation into California. CAA encourages producers to contact CalRecycle with any questions.
Advisory Board
An Advisory Board was established to consult with CalRecycle and CAA as the approved PRO on the implementation of SB 54. It is made up of 13 voting members and three nonvoting members appointed by CalRecycle. It includes representatives from local government, environmental and environmental justice organizations, manufacturers, recycling and solid waste enterprises, and retail and grocery associations. As the PRO, CAA serves as a nonvoting member.
CalRecycle has held two meetings with the Advisory Board, including one on March 8 in which CAA presented. For more information on the SB 54 Advisory Board, please visit CalRecycle’s Advisory Board landing page.
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