Wine Institute Comments on California SB 54 Packaging EPR Proposed Regulations

Wine Institute submitted comments on Oct. 7, 2025, regarding SB 54 (Allen 2022), the Plastic Pollution Prevention and Packaging Producer Responsibility Act, for which CalRecycle began the formal rulemaking process in August. The proposed language excludes CRV beverage containers from the program as required by statute but continues to include their secondary and tertiary packaging as “covered material” that must be accounted for under the act. The language excludes packaging that complies with specified federal requirements, such as food safety for agriculture, and provides exemptions for small businesses with less than $1 million in gross sales annually in California. Wine Institute also signed on to coalition letters with California Chamber of Commerce and Agricultural Council. Members of the Wine Institute Recycling Subcommittee received an overview of the proposed final language on Sept. 19 and provided feedback to the State Relations staff to inform our comments