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 opened an updated registration portal for producer registration. Companies that sell packaged products under their brand names are likely to have obligations under the law. CAA is urging producers to register with them by September 5, 2025. In addition to registration, CAA will also open a producer data reporting period, with a reporting deadline of November 15, 2025. 

The regulatory process to implement SB 54 is still underway. On March 7, 2025, Governor Newsom rejected CalRecycle’s initial draft regulations, citing concerns that the proposed rules would impose excessive costs on businesses and consumers. On August 22, 2025, CalRecycle opened the public comment period for its revised draft regulations, which will conclude on October 7, 2025. 

For their compliance needs, ISPA encourages its members to visit the website for Circular Action Alliance (CAA). Please reach out to ISPA’s Government Affairs team (Alison Keane, Grant Johnson, and Marty Salamone) if you have any questions.