Circular Action Alliance Accelerates Operationalization in California, Building Robust Framework for SB 54 Implementation

FOR IMMEDIATE RELEASE: May 22, 2025

WASHINGTON, DC – As Circular Action Alliance (CAA) enters a critical phase of operationalizing its comprehensive strategy for California's Extended Producer Responsibility (EPR) law, SB 54, the organization is advancing implementation in several areas. This progress marks a pivotal moment in establishing the necessary systems and frameworks to advance the plan for meeting the state's ambitious recycling and packaging waste reduction goals. 

“CAA’s work on California’s SB 54 is entering an accelerated phase,” said Jeff Fielkow, CEO. “With the informal rulemaking period underway and final regulations on the horizon, we’re intensifying our focus on building a robust program plan, reimbursement mechanism to enhance the recycling system, and reporting systems to meet California’s ambitious recycling and waste reduction goals.” 

Program Plan Development 

A cornerstone of this effort is the development of a comprehensive program plan for submission to the regulator next year. CAA continues to expand its national and state teams along with external expert partners that will support building critical plan elements including reuse and refill investment, source reduction planning, education and outreach, stakeholder consultation, and recycling and compost funding and infrastructure development. 

Source Reduction 

CAA has launched a dedicated project to develop the organization’s approach to meet the source reduction mandates under SB 54. This initiative aims to build a model that will empower producers to effectively achieve reduction goals. The plan will address two key areas:  

• Incentive System: CAA will develop an incentive system designed to encourage and reward efforts to accelerate source reduction. 

• SB54 Reporting Requirements: CAA will outline the specific steps and associated costs necessary for producers to accurately report their progress as mandated by SB 54. 

Reimbursement Methodology 

CAA is actively developing the reimbursement methodology, a vital framework that will provide financial support for California’s transition to enhanced recycling systems. This work involved three interconnected workstreams: 

• System-Wide Database: CAA is compiling a comprehensive database that will provide a complete picture of California’s recycling systems today and into the future, including participants, programs and material flows. This database will serve as a crucial resource for determining the new, additional and future costs associated with implementing SB 54. 

• A Baseline Cost Assessment: Using recycling system costs from 2022 as a baseline, CAA is identifying and quantifying the incremental ("net new") costs directly attributable to meeting SB 54 requirements. Establishing this baseline allows for clear differentiation between existing and additional expenses, ensuring eligible new costs are reimbursed. 

• Streamlined Reimbursement Process: CAA is developing a clear, simplified and efficient reimbursement process. This includes defining eligibility criteria, establishing data reporting requirements, creating structured service agreements and outlining transparent procedures for application, review, payment, dispute resolution and reporting. The goal is to facilitate timely, accurate and verifiable reimbursements to local jurisdictions, recycling service providers and other relevant interested parties. 

Collectively, these efforts will establish a robust and transparent reimbursement process to fund critical investments such as expanded curbside collection, improved processing infrastructure and other enhancements to California’s recycling system. This forward-thinking approach will accommodate reimbursements for eligible expenses incurred since Jan. 1, 2023, while also anticipating future funding needs from 2027 onwards, relying consistently on clear documentation, service agreements and pre-approval processes as appropriate. 

Producer Reporting 

Drawing on valuable experience from Oregon's Recycling Modernization Act, CAA is enhancing its online portals to streamline producer registration and data reporting. This proactive step will ensure a smooth and efficient reporting process for participating producers, which will report 2023 supply data in 2025 according to the following schedule: 

• Aug. 1 – Portal opens for registration in California 

• Sept. 5 – Registration deadline 

• Sept. 15 – Portal opens for reporting 

• Nov. 15 – Reporting deadline 

Interest Holder Engagement 

To build a strong and effective program, CAA is actively engaging with producers, trade associations, local governments, service providers, end markets, environmental justice organizations, nongovernmental organizations and other interested parties. These ongoing dialogues are essential to deeply understand on-the-ground realities and ensure the program plan is both practical and effective. As CAA's work progresses, numerous additional opportunities for stakeholder input on specific program components will be announced, continuing a truly collaborative approach. 

Team Evolution 

To support this next phase of operationalization in California, CAA is implementing planned staff changes and is in the final stages of hiring several key operational roles at the state and national level. Rachel Wagoner, California executive director, will move into an external advisory capacity. This evolution builds on Wagoner’s engagement with CAA, involving an initial phase of leadership and internal assessment to build a strong California foundation. The significant operational progress in California and the evolving SB 54 regulatory landscape align to make this the optimal time for this planned evolution. 

As Rachel transitions to her external advisory capacity beginning in June, CAA will conduct a comprehensive search to identify an operational executive director to work with CAA’s national team on the development of the program plan and the expansion of the in-state team. 

"We appreciate Rachel's leadership and the foundation she has built for CAA in California," Fielkow said. "As we now turn our full attention to implementing the complex requirements of SB 54, we are committed to maintaining our momentum as we build our California team." 

Media Contact:  

For more information, please contact:  
media@circularaction.org  

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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 guided by Founding Members representing the food, beverage, consumer goods, foodservice and retail industries.