California’s Plastic Pollution Prevention and Packaging Producer Responsibility Act, SB 54, requires producers of single-use packaging and plastic food serviceware sold in California to assume financial responsibility for the lifecycle of those materials. This includes registering with the Circular Action Alliance (California’s approved Producer Responsibility Organization (PRO)) (the “CAA”) and funding efforts to mitigate plastic pollution.
In 2025, subject producers are required to submit detailed data to the CAA on the amount and types of packaging sold into California in the 2023 calendar year. This data will be used to determine fee assessments that will start in January 2027 and track compliance with source reduction goals. The following timeline governs such reporting:
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- August 1 – The CAA portal opens for registration in California.
- September 5 – Registration deadline.
- September 15 – Portal opens for reporting of 2023 data.
- November 15 – Reporting deadline.
Implications for Businesses
SB 54’s compliance requirements apply to a broad range of companies, including brand owners, manufacturers, importers and retailers. Businesses must determine whether they fall within the law’s definition of “producer” and, if so, register with the CAA, implement internal data tracking systems, and prepare for fee assessments that will commence in 2027. Failure to comply may result in enforcement actions by CalRecycle, including substantial daily penalties (up to $50,000 per day) and possible restrictions on the sale of products in California.
Next Steps
Businesses should immediately evaluate their packaging profiles, initiate data collection processes for product sales and register with the Circular Action Alliance to ensure timely registration and fee payments.
For assistance evaluating your company’s obligations under SB 54 and developing a compliance strategy, please contact Foster Garvey.
