SB 54 EPR Packaging Organization Submits Program Plan

On June 15, 2026, the Circular Action Alliance (CAA), the organization selected by CalRecycle to manage the Extended Producer Responsibility (EPR) program for packaging in California, submitted its program plan to the SB 54 Packaging Producer Responsibility Advisory Board, which plans to discuss it on June 26. The regulatory package for the program was finalized by the Office of Administrative Law on May 1, 2026. The EPR program plan, mandated in SB 54 (Allen 2022), is the blueprint and framework for the program’s implementation by CAA and is now available for public comment; view the press release. Wine beverage containers accounted for under the Bottle Bill are exempt from the EPR program, but wineries may still have obligations for secondary and tertiary packaging such as case cartons and pallet wrap. Wineries should review with individual counsel as to whether they meet the requirements of a packaging producer under the packaging EPR program. Wine Institute is currently reviewing the CAA’s program plan and will submit any comments by the deadline of Aug. 14. Review the plan and other information here and share your EPR Packaging program input and comments with Anna Ferrera.