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On May 1, 2026, the Office of Administrative Law approved and filed regulations accompanying California’s Senate Bill 54 (SB 54). The regulations were effective as of the May 1 filing date. Also on May 1, CalRecycle published a web page with compliance guidance and information for producers.
Due to the effective status of the regulations, producers must take one of the following actions by June 1, 2026:
- Producers complying with the program through the approved producer responsibility organization (PRO) plan must register with Circular Action Alliance (CAA) and must submit required data to CAA.
- Producers complying individually must apply to be an independent producer and register with CalRecycle.
- Producers seeking to qualify for the small producer exemption must register with CalRecycle and apply for the exemption.
Producers that fail to register, submit data, and/or qualify for an exemption on or before June 1, 2026, may face penalties or administrative action from CalRecycle. Meeting the deadline ensures that producers stay in compliance and remain in good standing with the state program.
SB 54 is California’s Plastic Pollution Prevention and Packaging Producer Responsibility Act. The law establishes an extended producer responsibility (EPR) program. EPR programs seek to shift end-of-life product costs upstream along the product value chain. For more information about SB 54 and compliance requirements, visit CalRecycle’s SB 54 web page. Our EPR practice area page provides additional information about state programs, compliance tactics, and important considerations for producers.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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