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8 July 2025

CalRecycle Releases Latest Draft Of Regulations For California's Plastic & Packaging EPR Law

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Greenberg Glusker Fields Claman & Machtinger

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On July 1, the California Department of Resources, Recycling, and Recovery (CalRecycle), a California agency tasked with implementing the state's sustainability laws, released its latest draft...
United States California Environment

On July 1, the California Department of Resources, Recycling, and Recovery (CalRecycle), a California agency tasked with implementing the state's sustainability laws, released its latest draft of regulations for California Senate Bill (SB) 54, the Plastic Pollution Prevention and Packaging Producer Responsibility Act.

SB 54 is a so-called "Extended Producer Responsibility" (EPR) law with the goal of reducing single-use plastic packaging and foodware by shifting the cost of processing these materials to their producers, rather than consumers. This is done primarily by establishing a Producer Responsibility Organization (PRO), an entity to which producers join and pay fees. The PRO then implements and funds waste management, recycling, and waste reduction practices.

This latest draft of regulations comes after California Governor Gavin Newsom told regulators to go back to the drawing board on the day the regulations were originally due, March 7, 2025, citing concerns about the potential costs to businesses and consumers. The current draft was submitted to the Department of Finance as part of its review. According to CalRecycle, this draft is anticipated to be close to the version that will be released for the formal 45-day comment period required for rulemaking.

We will continue to monitor CalRecycle for updates as the details of SB 54's implementation are being hashed out over the coming months.

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