On May 1, 2026, California’s Department of Resources Recycling and Recovery (CalRecycle) announced that the Office of Administrative Law officially approved and filed the regulations to implement for the Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54), also known as California’s packaging Extended Producer Responsibility (EPR) law. With this approval, the regulations are now in force and bring important compliance deadlines for covered producers.
What else was announced:
- New Online Portal: CalRecycle has launched the Packaging Extended Producer Responsibility System (PEPRS) to handle producer registration, reporting, document submissions, and compliance tracking.
- Guidance Materials: CalRecycle will issue new guidance for producers, including tools to help determine if you’re covered and how to identify regulated materials.
If your business is subject to California’s packaging EPR law, you must now take action by June 1, 2026:
- Register with the Producer Responsibility Organization (PRO):
California previously approved Circular Action Alliance (CAA) as the state’s PRO. With the effective rules, covered producers now have a legal obligation to register and submit packaging data to the CAA. - Comply Individually:
The statute and rules do allow producers to forgo PRO registration if they elect to meet the program’s requirements individually as an Independent Producer. - Small Producer Exemption:
California’s Packaging EPR law allows exemptions for small producers but they are not automatic, like in other states. The final regulations include the requirements to register and apply for an exemption if a producer qualifies.
If you’re a producer of single-use packaging or single-use plastic food service ware in California, review CalRecycle’s new regulations and upcoming guidance and ensure you’re registered and compliant by the June 1 deadline. For questions, Please reach out to Jake Bartlett, David Edelstein or your Vorys Attorney.