Circular Action Alliance (CAA), the Producer Responsibility Organization (PRO) implementing California’s Extended Producer Responsibility (EPR) law (CA SB 54) for paper and packaging has set a November 15, 2025, deadline for voluntary initial producer reports. Producers are being asked to report their 2023 packaging data. CAA is requesting the data for use in developing its producer responsibility plan that will be submitted to California’s Department of Resources Recycling and Recovery (CalRecycle).

Notably, the November 15 deadline is not a statutory or regulatory deadline under SB 54. As such, CalRecycle considers it to be voluntary. The data will be a baseline for future source-reduction goals required by SB 54 and will inform CAA’s producer fee estimates. Producers will not be required to pay fees until 2027.

CalRecyle is still finalizing the regulations for SB 54. Earlier this year, Governor Newsom rejected CalRecycle’s initial draft regulations, citing concerns that the proposed rules would impose excessive costs on businesses and consumers. CalRecycle closed the public comment period for its revised draft regulations on October 7, 2025. 

California is the third U.S. state with a packaging reporting deadline in 2025. Initial producer reports under Oregon’s paper and packaging EPR law were due March 31, 2025, while initial reports under Colorado’s paper and packaging EPR law were due July 31, 2025. For their compliance needs, ISPA encourages its members to visit the producer resource center on CAA’s website. Among other resources, CAA has produced specific packaging EPR guidance documents for Colorado and Oregon, and California. Please reach out to ISPA’s Government Affairs team (Alison Keane and Marty Salamone) if you have any questions.