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California’s SB 54 EPR Packaging Law Rulemaking for Permanent Regulations Begins

For Senate Bill (SB) 54, the Department of Resources Recycling and Recovery (Cal Recycle) is putting up permanent regulations.

The Plastic Pollution Prevention and Packaging Producer Responsibility Act, established by SB 54, mandates minimum content standards for single-use plastic food service ware and packaging, which must be met through an extended producer responsibility (EPR) program.

The most substantial revision to California’s recycling regulations for plastics and packaging in history is the state’s historic packaging law. It takes a huge step toward a more circular economy, which is crucial to halting climate change, and goes farther than any other state in reducing single-use plastic at its source.

In contrast to other California EPR systems that govern less than 1,000 producers, the bill creates the state’s largest EPR program by regulating thousands of producers, up to an estimated 5,741.

The law transfers the responsibility for plastic pollution from consumers to manufacturers, usually the businesses who make or package goods in single-use plastic food service ware and packaging. $5 billion over ten years, or $500 million annually starting in 2027, must be paid by producers to: Address the environmental impacts of plastic pollution and

· Aid affected environmental justice communities most impacted by the damaging effects of single-use plastic waste.

The law requires producers to ensure that by 2032:

· 100% of single-use packaging and single-use plastic food service ware sold in the state is recyclable or compostable.

· 65% of single-use plastic packaging and single-use food service ware is recycled; and

· 25% reduction, compared to 2023, in the sale or distribution of single-use plastic packaging and single-use food service ware.

The law requires Cal Recycle to adopt permanent regulations.

The regulatory process for the Permanent Regulations of Senate Bill 54, the Plastic Pollution Prevention and Packaging Producer Responsibility Act, was formally started on August 22, 2025, by California’s Department of Resources Recycling and Recovery (Cal Recycle). This law creates an extended producer responsibility (EPR) system that transfers the cost of plastic pollution from consumers to producers—that is, businesses that produce or package goods in single-use plastic food service ware or packaging.

Cal Recycle published the Notice of Proposed Action, Proposed Regulation Text, and Initial Statement of Reasons as part of the procedure. Cal Recycle will hold a hybrid public hearing on October 7, 2025, the same day that these documents are available for public review.

Important measures including required producer registration, the establishment of a Producer Responsibility Organization (PRO), and yearly reporting requirements for covered goods are all outlined in the proposed regulations. They also describe Cal Recycle’s oversight and enforcement obligations under the Act, as well as compliance schedules, enforcement procedures, and sanctions for infractions.

When these regulations are finalized, they will offer the long-term structure for carrying out SB 54’s historic objectives of lowering the use of single-use plastics and guaranteeing that by 2032, all single-use packaging and single-use plastic food service in California be recyclable or compostable.

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