Supporting California’s Transition to Producer Responsibility as SB 54 Regulations Take Effect
By Emily Coven, California Executive Director, Circular Action Alliance
California’s complex waste and recycling system serves communities with diverse needs, infrastructure and service models. Packaging represents a significant share of materials moving through that system, and the Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54) establishes a new framework to better align responsibility, funding and performance as California looks to improve waste reduction and recycling outcomes statewide.
With SB 54 regulations finalized on May 1, the state is entering a new phase focused on supporting a more coordinated, transparent and accountable approach to managing packaging from collection to responsible end markets.
From Policy to Implementation
With SB 54 California introduced extended producer responsibility (EPR) for single-use packaging and plastic food serviceware, shifting certain financial and operational responsibilities upstream while preserving the foundational role of local governments and service providers. The regulations now establish the framework for how data will be collected, how funding will flow, and how progress will be measured over time.
As the nonprofit Producer Responsibility Organization (PRO) appointed by CalRecycle to develop and administer the EPR program plan under SB 54, CAA is now turning from planning to implementation. Our focus in the coming months centers on building the systems needed to make the program operational, drivenby data and informed by interest holder input while understanding the realities of existing local programs.
Why Early Data Matters
May is an important month for SB 54 compliance. With regulations now in effect, obligated producers must either register with CAA and report 2023 baseline supply data, or apply to CalRecycle as an independent producer. In addition, the 2026 California Producer Report (2025 Data Year) and the 2026 California Annual Source Reduction Report (2025 Data Year) are due May 31, 2026.
Producers’ early participation, including timely data submission and registration, plays an important role in supporting informed planning and smooth implementation.
This month also marks the launch of CAA’s California Recycling and Reuse System Optimization Project (CARRSOP), which aims to engage statewide interest holders and build on the statewide needs assessment to capture estimated implementation costs on a more granular level.
This information is foundational. Accurate, early data allows regulators and program administrators to better understand the current packaging landscape, identify specific system needs and budget responsibly for future investments. It supports transparency, informs program design and helps ensure that producer funding is aligned with real conditions across California’s diverse communities.
CAA appreciates in advance the participation in this project by entities involved in operating California’s recycling and reuse systems, including local jurisdictions, haulers, transfer stations, MRFs, organics processors, end markets, and reuse program and service providers.
A Systemwide Approach
SB 54 is structured to complement and support existing collection and recycling systems. It recognizes the essential role that local governments and service providers already play, while introducing accountability and a stable funding mechanism tied to single-use packaging and plastic food serviceware placed on the market.
At its core, the law reflects a shared responsibility model. Producers, governments, service providers and communities each have defined roles, with the goal of reducing waste, increasing recycling rates and minimizing environmental impacts over time.
CAA’s Role as Implementer
CAA’s responsibility is to carry out the requirements established in the regulations, in coordination with CalRecycle and through engagement with interest holders across the state. This includes providing communities statewide with equitable access to program benefits, developing data‑driven systems, supporting compliance and ensuring that producer funding is managed in a manner consistent with regulatory direction.
We are committed to transparency, collaboration and responsible stewardship as we operationalize California’s milestone law and ambitious waste reduction targets. Implementation will build on existing programs and infrastructure, with a focus on supporting statewide consistency while respecting local conditions and needs.
Looking Ahead
With regulations now in effect, CAA is preparing to submit its program plan on June 15, outlining proposed implementation pathways across recycling, reuse and source reduction that are consistent with the regulatory framework.
Following submission, a public comment period will run through August 14, providing interest holders an opportunity to review and share input on the proposed approach. This process ensures the implementation plan is grounded in real system conditions and informed by a broad range of perspectives.
In parallel, CAA will continue gathering detailed data about the state’s recycling and reuse systems through CARRSOP.
Early implementation activities are focused on testing approaches in areas where systems and pathways are still being defined, including pilot projects for challenging material streams such as plastic film and flexible packaging to evaluate collection and processing feasibility, as well as the public consultation on the Responsible End Markets (REM) Standard to help define and verify responsible end markets. These efforts provide critical inputs to program design and implementation planning.
Overall, these initiatives reflect a structured implementation process, with early data, testing and interest holder input informing how SB 54 requirements are applied and sequenced over time within the regulatory framework.
Through coordinated efforts, California will take meaningful steps toward reducing waste and strengthening recycling outcomes statewide. We look forward to your collaboration as implementation progresses.