SB 54 · enacted 2022

California packaging EPR: what you owe and when

Plastic Pollution Prevention and Packaging Producer Responsibility Act. Current phase: Registration open, fee schedule not final.

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Am I covered

You are a producer if you own the brand on covered packaging or plastic food service ware sold, offered for sale, or distributed in California. Where the brand owner has no presence in the United States, the obligation moves down the chain to the importer, and then to the person who first distributes the item in the state.

Source: California Public Resources Code, Plastic Pollution Prevention and Packaging Producer Responsibility Act , PRC Division 30, Part 3, Chapter 3. Verified 12 August 2026.

The exemption

Producers with under one million dollars in gross sales in California in the most recent calendar year may apply for an exemption. It is not automatic. You must register with CalRecycle and apply through PEPRS, and you must receive written confirmation before you leave any material out of a supply report. An approved exemption runs for two years and can be renewed.

Source: CalRecycle small producer exemption guidance . Verified 12 August 2026.

What the threshold is measured against

Gross sales in California, not global revenue and not units shipped. States differ on this, so a company exempt in one may be obligated in another on the same turnover.

Source: CalRecycle small producer exemption guidance . Verified 12 August 2026.

What you owe

Registration

Register with CalRecycle through PEPRS, and join the producer responsibility organization or apply to operate independently. Registration applies even if you expect to qualify for the small producer exemption, because the exemption is applied for rather than assumed.

Source: CalRecycle, Packaging EPR programme page . Verified 12 August 2026.

Who runs the programme

Circular Action Alliance, approved as the first producer responsibility organization for California packaging.

Source: CalRecycle, Packaging EPR programme page , PRC 42061.5. Verified 12 August 2026.

Reporting

Report the packaging and plastic food service ware you supplied into California, by material category and weight, through your producer responsibility organization.

Source: CalRecycle, Packaging EPR programme page . Verified 12 August 2026.

Fee schedule

California has not published a final fee schedule. Rates published so far are illustrative and the regulator has said they will be revised. We will not fill that gap with another state's numbers or a national average, because a budget built on either is wrong in a way you cannot see.

Eco-modulation

Not yet confirmed. Final bonus and malus percentages and their qualifying conditions. CAA has published illustrative figures that it states are non binding and will be revised, so nothing here is final. We would rather show you a gap than a plausible number.

Timing: the year you sell is not the year you pay

This is the part that catches people out. Packaging you sell in one year is reported the next and invoiced after that, so the cost lands in a later budget than the sales that created it.

2025 You sell packaging into California. This is the data year.
2026 You report that year's supply.
2026 You are invoiced for it. Budget the cost here, not against the year you sold.

Source: Programme timing not yet documented for this state.

If you do not comply

Up to $50,000 per day, per violation. For a continuing failure such as not registering or not reporting, each day counts as a separate violation. Penalties do not start accruing until 30 calendar days after you are notified of the violation, so a fast response after a notice materially limits the amount.

Source: California Public Resources Code section 42081 , PRC 42081. Verified 12 August 2026.

Recent changes

CalRecycle's SB 54 regulations took effect, setting the registration and reporting machinery producers now work to.

Source: CalRecycle rulemaking record . Verified 12 August 2026.

Run your own numbers

Enter what you supply into California, in pounds, against this state's own reporting categories. You get a fee with the public document behind every rate it used.

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