Circular Action Alliance California Submits Program Plan Under State Bill 54
Milestone marks transition from planning to implementation, advancing a practical path to meet SB 54’s ambitious targets
JUNE 15, 2026 — Circular Action Alliance California (CAA) today submitted its California program plan to the Packaging Producer Responsibility Advisory Board as required under California’s Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54), marking a key milestone in the state’s effort to reduce packaging waste and strengthen recycling and reuse systems.
The submission represents a shift from planning to implementation, signaling the transition to operationalizing a statewide program aligned with finalized regulations.
California’s SB 54 establishes a framework to improve how packaging is managed across the state, with defined roles for producers, local governments and recycling service providers. As the nonprofit Producer Responsibility Organization (PRO) appointed by CalRecycle, CAA is responsible for developing and implementing a program plan that meets statutory and regulatory requirements under state oversight.
“Today’s submission reflects the sustained collaboration that has shaped this work from the start,” said Emily Coven, CAA’s California Executive Director. “The plan draws on extensive input from across California’s recycling and reuse system and is designed to work in real-world conditions while enabling steady progress over time. We’re encouraged by the level of engagement to date and look forward to continuing this collaboration as implementation scales, advancing a more circular system.”
The program plan reflects a data-driven and collaborative approach, informed by technical analysis and engagement with producers, local governments, recycling service providers and other interest holders across the recycling and reuse system. It is designed to support a coordinated, transparent, and accountable approach to managing packaging materials from collection through end markets.
With regulations finalized on May 1, 2026, the state is entering a new phase focused on building the systems needed to enable implementation at scale. The plan outlines proposed pathways across recycling, reuse and source reduction, consistent with the regulatory framework.
Following today’s submission, the program plan enters a formal public comment period through Aug. 14, providing an opportunity for interest holders to review the proposal and share input as part of the program planning process.
"We have worked closely with producers, local jurisdictions, service providers and other interest holders to develop a robust plan, taking decisive action even ahead of final regulatory certainty,” said Shane Buckingham, Chief of Staff. “By launching the producer reporting process last year to build our source reduction plan and releasing fee-rate estimates this past May, we have provided the tools necessary for producers to prepare for the program. We have laid the foundation for a successful and pragmatic program and look forward to working with the public and the Packaging Producer Responsibility Advisory Board to finalize our path forward."
“SB 54 sets ambitious goals, and CAA’s role is to build a practical, scalable program that enables producers to meet those requirements under real-world conditions,” said Jeff Fielkow, Chief Executive Officer. “This submission is an important milestone, made possible by the dedication of our team and strong collaboration across producers, government, recyclers, and communities. We remain committed to working closely with CalRecycle and interest holders to develop a program that is effective, practical to implement, and capable of delivering the outcomes envisioned by SB 54.”
CAA’s early implementation activities include data collection and system optimization efforts to better understand infrastructure needs and inform future investments.
For more information on the California program plan and to participate in the public comment period, visit: https://circularactionalliance.org/ca/program-plan-public-comment
Media Contact: media@circularaction.org
About Circular Action Alliance
Circular Action Alliance (CAA) is a U.S. Producer Responsibility Organization (PRO) dedicated to implementing effective Extended Producer Responsibility (EPR) laws for paper and packaging. As a nonprofit, producer-led organization, CAA is committed to helping producers comply with EPR laws, delivering harmonized best-in-class compliance services and to working with governments, businesses and communities to reduce waste and recycle more. CAA was founded in 2022 and is led by producers representing the food, beverage, consumer goods, foodservice and retail industries.