California SB 54 – The Packaging EPR Revolution That Isn’t Quite Here Yet

October 8, 2025

On June 30, 2022, Governor Gavin Newsom signed into law Senate Bill 54 (SB 54), formally known as the Plastic Pollution Prevention and Packaging Producer Responsibility Act.  SB 54 is intended to be one of the most ambitious packaging and plastics laws in the U.S. — pushing the cost of packaging waste management onto the producers, setting circular economy goals, and restructuring how California handles packaging from “take, use, discard” to a shared responsibility model. 

But while the law’s vision is bold, its implementation has been far more complicated and delayed than expected. This article walks through the structure of SB 54, the current status (as of mid-2025), recent developments, and what steps brand owners and manufacturers need to take now.

 

What SB 54 Requires — The Core Provisions

 

Covered Materials / Scope

 

SB 54 applies to “covered materials,” which broadly include single-use packaging and single-use plastic food service ware sold in California. 

These materials span everything from primary packaging (e.g. a snack bag) to secondary or tertiary packaging (cartons, wrap, shipping materials), plus foodware like lids, straws, cups, trays, and utensils. 

However, the law also carves out exemptions for certain packaging categories, such as medical devices, durable packaging held for long-term use, infant formula containers, hazardous goods packaging, and others. 

Goals & Targets by 2032

 

The law sets aggressive goals to drive reduction, reuse, and recycling:

  • 100% of single-use packaging and plastic food service ware must be recyclable or compostable by 2032 

  • Achieve a 65% recycling rate for plastic packaging / foodware by 2032 

  • Reduce single-use packaging (by weight or by component) by 25% relative to 2023 levels 

 

Financial & Administrative Structure

 

To fund the system, SB 54 shifts costs of collection, processing, and recycling from municipalities and taxpayers to the producers (i.e. brand owners, manufacturers) via eco-modulated fees and producer payments. The law anticipates $5 billion in funding over 10 years (i.e. $500 million annually). 

A core element is the creation or appointment of a Producer Responsibility Organization (PRO) — an entity that pools resources, manages reporting, and executes recycling and management obligations on behalf of producers. In California, that organization is the Circular Action Alliance (CAA), selected by CalRecycle. 

CalRecycle is responsible for rulemaking, oversight, publishing lists of covered materials, rules for eco-modulation, and ensuring compliance. 

 

Status & Progress (2025) — Where Things Stand

 

Drafting, Delays, and Rulemaking Restart

 

Originally, SB 54 required that CalRecycle adopt permanent regulations by March 8, 2025 to implement the law’s provisions. 

However, due to concerns raised by businesses, cost estimates, and public comment volume, Governor Newsom directed a restart of the rulemaking process in March 2025. 

The state had published a first draft, collected 5,000+ public comments, and then reversed course — signaling the need to rebalance environmental ambition with economic feasibility. 

In May 2025, CalRecycle released an updated set of revised draft regulations, incorporating changes intended to clarify obligations, simplify fee structures, and extend exemptions for certain materials. 

Milestones & Timing

 

Some key milestones and deliverables to watch:

  • July 1, 2024 — CalRecycle was to publish its Covered Material Categories (CMC) List identifying which packaging materials fall under SB 54. 

  • CAA expects to submit its compliance plan and manage producer enrollments. 

  • Implementation for registration, reporting, and fee payment is expected to begin in phases, likely starting in 2027. 

 

Despite these efforts, the fact that the regulations have been delayed and the law has been reset has created uncertainty among industry participants. 

Pushback, Adjustments, and Industry Friction

 

Some of the friction points include:

  • Costs to business and consumers: A state analysis reportedly estimated the law could lead to $36 billion in cost and an extra $300/year per household. 

  • Implementation complexity: Defining who is an obligated producer, what is a “covered material,” fee methodology, exemption criteria, and data reporting are all contentious. 

  • Rollback concerns: Some industry observers see the rulemaking restart as a soft rollback, though no statutory changes have been made. 

  • Disadvantaged communities & equity: SB 54 emphasizes support for low-income and rural areas impacted by pollution. Provisions for how funding and mitigation will be distributed remain under scrutiny. 

 

 

Implications & Risks for Businesses

 

Who is “Obligated”

 

Under proposed regulations, responsibility for compliance cascades along the supply chain:

  1. The manufacturer of the packaging or foodware in many cases

  2. The California-based brand owner / importer if the manufacturer isn’t in CA

  3. Licensees or other entities with exclusive rights in California, if neither manufacturer nor brand owner qualifies

 

This means many out-of-state brands selling into California will be pulled into compliance. 

Data & Reporting Challenges

 

To comply with SB 54, producers will need to maintain detailed and auditable records of:

  • Material types and composition

  • Weight, volumes, components

  • Recycled content (PCR)

  • Recyclability / compostability assessments

  • Designation of reusable/refillable or eliminated packaging

  • Contracts and flow of materials through supply chain

 

If your data infrastructure is weak (inconsistent, siloed, ungoverned), compliance may become an uphill battle.

Financial Exposure

 

Producers will be required to pay into the system via contributions (fee mechanisms). Noncompliance can invite penalties. As the rulemaking is clearer, firms must anticipate cost exposure not only in operations but in reporting, auditing, and system upgrades.

Operational & Design Pressure

 

Compliance doesn’t just mean reporting — products will need to be reengineered for reuse, elimination, material substitutability, and recycling compatibility. Packaging design, procurement, supplier engagement, and testing infrastructure will need to shift.

Competitive Differentiation

 

Those who get ahead of SB 54 may gain an advantage: more sustainable packaging, faster market entry into CA, fewer retrofits, and improved brand position. Conversely, laggards risk disruption, fines, or exclusion.

 

How to Prepare — Practical Steps You Can Take Now

 

Given the uncertainty in regulation timing, but clear statutory obligations, here’s what forward-looking organizations should consider:

  1. Data readiness assessment

    Conduct a gap analysis: how complete and accurate is your packaging and material data? What’s missing or inconsistent?

  2. Map your portfolio to “covered materials”

    Use preliminary CMC lists and definitions from CalRecycle to classify which SKUs fall under SB 54. (Projects like this benefit from modular tools).

  3. Set up architecture for scalability

    Deploy or prepare systems (PLM, spec databases, compliance tools) to ingest, version, and export packaging data in required formats.

  4. Run small pilots

    Pick a few representative SKUs or packaging types. Simulate reporting to see where your assumptions fail. Use as proof-of-concept and learn before full rollout.

  5. Lock in supplier cooperation

    Packaging compliance depends on supplier transparency (resin data, PCR content, component weights). Engage suppliers early to ensure required data flows.

  6. Monitor regulatory developments & comment periods

    The rulemaking process is ongoing. Submit feedback, watch proposed drafts, and try to influence definitions, exemptions, or compliance timelines.

  7. Scenario modeling for cost & compliance

    Use your pilot data to model fees, redesign costs, packaging alternatives, and compliance exposures. That helps budget and strategic decision-making.

 

 

Conclusion: SB 54 — Visionary, Complex, and Ongoing

 

SB 54 is one of the most ambitious packaging and EPR laws in the U.S. It aims to shift responsibility, drive circular economy principles, reduce waste, and invest in recycling infrastructure. But the journey from statute to enforcement is more delayed and complex than many expected.

For producers and brand owners currently selling into California (or planning to), compliance is no longer optional. The switch from treating packaging as peripheral to central is underway, and the time to act is now — even while regulatory details are still being finalized.

The next few years will test who is ready to operate in a world where packaging isn’t just a cost center — it’s a data challenge, a design challenge, and a strategic imperative.

As your partner in specification data and packaging management, we at Dazmii help companies build the infrastructure, governance, and domain insight to survive and thrive under laws like SB 54 — no matter how the rulebook evolves.

Posted in EPR