SB 54 packaging rules are now real. After years of drafts and withdrawals, CalRecycle's permanent regulations took effect on May 1, 2026. The law, the Plastic Pollution Prevention and Packaging Producer Responsibility Act, makes brands pay for and improve the packaging they put on the California market.
Here's what SB 54 requires, the dates that matter, and the data you need.
Key takeaways
- Final SB 54 regulations took effect May 1, 2026.
- Covers single-use packaging (all materials) and plastic single-use food service ware.
- Producers must join the approved PRO (by January 1, 2027) or comply individually, and report data.
- By 2032: covered packaging must be recyclable or compostable; single-use plastic cut 25%.
What SB 54 covers
SB 54 applies to covered material: single-use packaging and plastic single-use food service ware sold, distributed or imported into California. Single-use packaging includes paper, plastic, glass, metal and multi-material packaging, not just plastic. Shipping boxes, retail cartons, poly bags, blister packs and inserts can all be covered.
There are exemptions, such as certain medical, hazardous materials and some packaging where alternatives are "not reasonably possible." The regulations require producers to file notice and justification with CalRecycle to exclude such packaging from reporting.
Who is the producer
Usually the brand owner of the product in the packaging. If there's no in-state brand owner, the licensee, importer or distributor may be the producer. E-commerce shipping packaging has its own rules. Our post on who is the producer under SB 54 covers the edge cases.
Small producers below the revenue threshold can apply for an exemption.
Key dates
| Date | Milestone |
|---|---|
| 2022 | SB 54 signed |
| January 9, 2026 | Draft regulations withdrawn for revision |
| March 19, 2026 | Revised regulations submitted for final review |
| May 1, 2026 | Permanent regulations approved and effective; PEPRS portal launched |
| June 1, 2026 | Deadline to register as an independent producer or apply for small-producer exemption |
| January 1, 2027 | Deadline to join the PRO (per CalRecycle statements) |
| 2028 onward | Interim recycling and source reduction milestones |
| January 1, 2032 | 100% of covered material recyclable or compostable; 25% single-use plastic reduction; 65% plastic recycling rate |
CalRecycle's portal for registration and data is called PEPRS (Packaging Extended Producer Responsibility System). The Circular Action Alliance is the approved PRO.
What producers must do
- Determine producer status for each product sold in California.
- Join the PRO or apply to comply independently.
- Report covered material supplied into California: by material type and weight, with additional data the PRO and CalRecycle require.
- Pay fees set by the PRO, which vary by material and recyclability.
- Redesign over time to meet source reduction and recyclability targets.
The data you need
For each SKU sold into California:
- Every packaging component (primary, secondary, shipping)
- Material and resin type
- Weight per component
- Units sold into California
- Recyclability or compostability status
- Recycled content, if known
This is the same backbone data Oregon, Colorado and other EPR states use. See packaging EPR laws by state.
SB 54 and PFAS
SB 54 isn't a chemical law, but packaging and PFAS overlap. California already bans intentionally added PFAS in plant-fiber food packaging (AB 1200). When you request packaging specs for SB 54, ask about PFAS at the same time.
Practical first steps
- Inventory packaging for your top 20 SKUs first.
- Send packaging suppliers one request for material, weight, recycled content and PFAS status.
- Get California unit volumes from e-commerce and wholesale reports.
- Confirm PRO membership before January 1, 2027.
- Flag hard-to-recycle components for redesign.
Example: one product's SB 54 picture
A cookware brand sells a 10-inch pan in California. Its packaging:
| Component | Material | Covered? | Notes |
|---|---|---|---|
| Printed retail box | Paperboard | Yes | Recyclable in most programs |
| Plastic window | PET film | Yes | Mixed material reduces recyclability; consider removing |
| Molded pulp insert | Molded fiber | Yes | Check for PFAS grease-resistant treatment |
| Cardboard sleeve | Corrugated | Yes | Easy to recycle |
| DTC shipping box | Corrugated | Yes (shipping packaging) | Reported by the party shipping to the consumer |
Two quick wins: drop the plastic window and confirm the molded pulp insert has no PFAS treatment.
Source reduction and recyclability targets
SB 54's long-term goals push design changes, not just reporting:
- 25% reduction in single-use plastic packaging by 2032 (by weight and number of components, per the law's method)
- 65% recycling rate for covered plastic packaging by 2032
- 100% recyclable or compostable covered material by 2032
The PRO sets fees that reward progress. Start redesigns early; packaging lead times are long.
Questions teams ask
"Is shipping packaging covered?" Generally yes. The party that packs and ships to California consumers may be the producer for that packaging. See SB 54 producer definition.
"We're a small brand. Are we exempt?" Possibly, if under the revenue threshold. The application window opened after the regulations took effect.
"Do we need to report every SKU separately?" You need accurate totals by material. Building them up from SKU-level data is the most reliable way.
SB 54 checklist
- Producer status confirmed for each product and channel
- Small-producer exemption checked
- PRO membership in place before January 1, 2027
- Packaging inventory with material and weight per component
- California unit sales by SKU
- Shipping packaging responsibilities agreed with 3PLs and marketplaces
- Hard-to-recycle components flagged for redesign
- PFAS status checked on fiber-based food packaging
What to do this week
- Confirm your PRO status with the Circular Action Alliance or CalRecycle, and note the January 1, 2027 deadline.
- List packaging components for your top 20 California SKUs.
- Ask your 3PL or marketplace partners in writing who reports shipping packaging.
- Flag one easy redesign, like removing a plastic window or a mixed-material insert.
Key terms
- Covered material: Single-use packaging and plastic single-use food service ware under SB 54.
- PEPRS: CalRecycle's Packaging EPR System portal for registration and data.
- PRO: The producer responsibility organization; the Circular Action Alliance in California.
- Source reduction: Cutting single-use plastic packaging by weight and number of components as the law sets out.
- Independent producer: A producer approved to comply on its own instead of through the PRO.
Mistakes to avoid
- Treating SB 54 as plastic-only; paper, glass and metal packaging are covered.
- Forgetting shipping boxes and mailers.
- Estimating weights instead of measuring.
The bottom line
SB 54 is now a working program with final rules, a portal and deadlines. Confirm producer status, join the PRO before January 1, 2027, build packaging data by SKU, and start redesigning hard-to-recycle components ahead of the 2032 targets.
How Secuabase helps
We collect packaging specs and declarations from your suppliers and turn them into a clean, reusable packaging data set by SKU and material, ready for SB 54 and other state reports.
For our first partners we run it free on one product line. Book a quick chat.
FAQ
What is SB 54?
California's packaging EPR law requiring producers to join a PRO, report data and meet targets.
When did regulations take effect?
May 1, 2026.
What happens by 2032?
Covered packaging must be recyclable or compostable, with a 25% cut in single-use plastic.
General information, not legal advice. Confirm with CalRecycle and your PRO. Facts checked October 2026.
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