On May 1, the California Department of Resources Recycling and Recovery (CalRecycle) announced the approval of permanent regulations for the Plastic Pollution Prevention and Packaging Producer Responsibility Act (CA SB 54). The regulations became effective upon filing with the California Secretary of State. CalRecycle published a guidance webpage with updated resources for producers and plans to publish additional guidance materials soon.

Obligated producers in California have until June 1, 2026, to do one of the following:

  • Register with Circular Action Alliance (CAA), the state-approved Producer Responsibility Organization (PRO), and submit packaging supply data to CAA.
  • If complying individually, register with CalRecycle and apply to be an independent producer.
  • If qualifying for an exemption for small producers, register with CalRecycle and apply for the small producer exemption.

In addition to the packaging supply data deadline, by August 1, 2026, producers must submit individual source reduction plans to CAA that outline how they will meet SB 54’s statutory reduction targets. CalRecycle published this guidance document on source reduction reporting.

As ISPA recently reported, five other states, in addition to California, have Packaging EPR reporting deadlines on May 31, 2026. For their compliance needs, ISPA encourages its members to visit the website for Circular Action Alliance (CAA). 

Soon after the regulations were finalized, Californians Against Waste and the Natural Resources Defense Council announced their intent to file a lawsuit against CalRecycle. Both environmental groups argue that CalRecycle’s final regulations violate the law by allowing exemptions for certain packaging types and advanced recycling to potentially count toward recycling goals. Business groups may also sue the agency over the final regulations.

Please contact ISPA’s GA Team (Alison Keane, Shawn Swearingen, and Marty Salamone) if you have any questions.