California
California’s Plastic Pollution Prevention and Packaging Producer Responsibility Act requires producers of residential and commercial single-use packaging and plastic single-use food service ware to join a Producer Responsibility Organization (PRO), and through the PRO, fund the end of life of those materials, which includes processing and recycling. Additionally, the PRO must remit to the state $500 million each year, starting in 2027 and ending in 2037 to be placed in the California Plastic Pollution Mitigation Fund.
On January 8, 2024, CAA was selected by CalReycle as the state’s inaugural, single PRO.
FAQ
Key Information for Producers
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On January 8, 2024, CAA was selected by CalReycle as the state’s inaugural, single PRO.
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To comply with producer registration requirements under California, Colorado, and Oregon EPR laws for paper and packaging products, covered producers must register with CAA unless the producer qualifies for an exemption or the producer intends to submit an individual compliance plan, under applicable law.
Regulations in Colorado required producers to register by October 1, 2024. Producers who did not register by that date may be subject to enforcement. CAA will be submitting a list of registered producers to the Colorado Department of Public Health & Environment following the October deadline. CAA will be submitting a list of registered producers to the Colorado Department of Public Health & Environment as required.
CAA was required to provide the Oregon DEQ with a list of registered producers as part of CAA’s revised program plan, submitted on September 27, 2024.
Producers in these states who missed the deadline need to still register with CAA.
Only registered producers will gain access to CAA’s producer education forums, such as the Producer Working Group (PWG), and receive detailed guidance to support data preparation and reporting.
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California, Colorado, Maine, and Oregon EPR laws have different fee collection requirements and timelines. Oregon will be the first state where producers have fee obligations when the program begins on July 1, 2025. Fee obligations in Colorado will begin in January 2026. In California, fee obligations start in January 2027.
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CAA has set a preliminary reporting deadline in California of August 31, 2025.
Each state will have specific reporting categories for all materials in scope of the program, whether or not they are determined to be recyclable. Producers will report the type and weight of their covered materials into these categories.
Producers can expect detailed guidance on reporting to be released in late-October 2024. Only registered producers who have a signed a Participant Producer Agreement (PPA) with CAA will be able to access the reporting guidance. The PPA outlines the terms and conditions between producers and CAA and will be available to registered producers in late-October.
CalRecycle may develop rules to clarify the date by which producers must report information to the PRO, and CAA will develop guidance to support producers with packaging data reporting.
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On March 7, 2025, Governor Gavin Newsom directed CalRecycle to restart regulations for SB 54, the state’s landmark plastic reduction law. While the reopening of rulemaking introduces a period of review, CAA is fully prepared to adapt our implementation strategy as needed. The additional time provided for refining the regulations will allow CAA to address critical elements and ensure the program’s long-term success. We deeply appreciate the continued collaboration and engagement of all interested parties and emphasize the importance of open dialogue throughout this process.
CAA will provide timely updates to producers and all interested parties as new information becomes available. Moving forward, we will continue to build our team and enhance our capabilities to ensure a robust and successful implementation.
Key Milestones in the Regulatory and Implementation Process
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June 30, 2022
Governor Newsom Signs SB 54.
Updates
Rulemaking
Formal rulemaking for SB 54 began on March 8, 2024. CAA has been engaged and submitting comments throughout the process. On March 7, 2025, Governor Gavin Newsom directed CalRecycle to restart regulations for SB 54. While the reopening of rulemaking introduces a period of review, CAA is fully prepared to adapt our implementation strategy as needed.
Please refer to CalRecycle’s Plastic Pollution Prevention and Packaging Producer Responsibility Act Permanent Regulations page for additional details included proposed regulation text and related documents.
On December 31, 2024, CalRecycle published the plastic source reduction baseline and the Source Reduction Baseline Technical Report, outlining the methodology that informed the development of the baseline.
Compliance
CalRecycle released an updated Covered Material Category list on July 1, 2024. Updates to the recyclability and compostability determinations for the list were released on December 31, 2024. SB 54 requires CalRecycle to use criteria established by SB 343 to evaluate the potential recyclability and compostability of covered material categories. Learn more on CalRecycle’s Accurate Recycling Labels page.
On September 11, 2024, CalRecycle provided notification on the upcoming SB 54 deadline concerning expanded polystyrene food service ware. Prior to January 1, 2025, producers of expanded polystyrene food service ware were required to demonstrate to CalRecycle a recycling rate of not less than 25% of all expanded polystyrene food service ware sold into California. If this demonstration was not adequately made, expanded polystyrene food service ware will be prohibited from sale, offering, distribution or importation into California. CAA encourages producers to contact CalRecycle with any questions.
Advisory Board
An Advisory Board was established to consult with CalRecycle and CAA as the approved PRO on the implementation of SB 54. It is made up of 13 voting members and three nonvoting members appointed by CalRecycle. It includes representatives from local government, environmental and environmental justice organizations, manufacturers, recycling and solid waste enterprises, and retail and grocery associations. As the PRO, CAA serves as a nonvoting member.
For more information on the SB 54 Advisory Board, please visit CalRecycle’s Advisory Board landing page.
