CA Approves SB 54 Packaging EPR Regulations

On May 1, 2026, the Office of Administrative Law (OAL) approved the permanent regulations for the SB 54 Extended Producer Responsibility (EPR) Program and filed them with the secretary of state. The regulations became effective upon that filing. The Circular Action Alliance (CAA), the designated producer responsibility organization (PRO) managing the program, has advised that product manufacturers consult with legal counsel to determine whether they are producers under the new program that is focused on reducing packaging waste.

Producers now have 30 days to do one of the following:

  • If participating in the approved producer responsibility organization (PRO), register with Circular Action Alliance (CAA) and submit supply data to CAA.
  • If complying individually, register with CalRecycle and apply to be an Independent Producer.
  • If qualifying for an exemption for a small producer, register with CalRecycle and apply for the Small Producer Exemption.

These requirements must be met no later than June 1.

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