California SB 54 Packaging EPR Proposed Regulations

On May 18, 2025, released revised proposed regulations to implement an Extended Producer Responsibility (EPR) program for single-use packaging required by SB 54 (Allen, 2022) and held a public workshop on May 27 to gather informal feedback from stakeholders. The revised language includes categorical exemptions for secondary/tertiary packaging of CRV products and for packaging subject to federal food and ag laws. The new language is already facing pushback from environmental groups that are concerned the exceptions are too broad. Wine Institute will submit written comments by the June 3 deadline to support and clarify the proposed EPR language and will also join CalChamber on a broader, business-focused comment letter. CalRecycle is expected to review feedback on this draft package and will begin a formal rulemaking on revised language later this year. Contact Anna Ferrera for more information.