EPR SB 54: New Packaging legislation in California

What does the newest California Packaging legislation mean for your business?

‍

The newest legislation—SB 54—signed by Governor Newsom in July of 2022 will result in an extended producer responsibility for for all single-use packaging materials, including plastic, paperboard, glass, and metal, as well as plastic single-use food service ware. The bill aims to increase the producer’s responsibility for treating and disposing of post-consumer products and decrease single-use packaging. The bill requires brands to disclose data on packaging materials—in other words, it introduces a data reporting requirement as part of compliance.

‍

EPR law shifts the cost of recycling packaging from consumers to the companies that put packaging on the market. If you sell packaged goods, import products, or offer private-label items, you may now be responsible for reporting and compliance.

‍

Why CPG brands?

Think of it as "you packaged it, you manage it." Companies are now responsible for the end of life cycle of the products they produce and must report packaging data and eventually pay fees to support waste management infrastructure.

‍

Here are the basics you need to know:

CPG brands selling over $1 million annually in California with covered packaging materials (plastic, paper, glass, metal, and compostable materials), must register with the Circular Action Alliance (CAA), the primary Producer Responsibility Organization (PRO) for all US EPR programs. Unlike other states, California requires each registered producer to report individually—no consolidated reporting exemptions available.

Register with CAA by September 5, 2025. Submit 2023 packaging data by November 15, 2025 after signing your California Interim State Addendum (CAISA) in September-October.

‍

We know compliance can feel overwhelming, which is why we’re sharing a helpful resource from our friends at rePurpose. Their free EPR Assessment Quiz makes it easy to see if your brand is affected and what steps you may need to take.

‍

^{Disclaimer: The U.S. Packaging landscape is moving fast and rapidly changing. Moquin Press tries to ensure accuracy and up-to-date information, however there may be things covered that will or have changed. This is intended for general informational purposes only and should not be interpreted or relied upon as legal advice.}