California SB 54 explained: a plain-English guide for brands

By Shekhar Nirkhe, Founder, ZeeHub. Last updated November 2026.

California SB 54 is the state’s packaging extended producer responsibility (EPR) law. It requires producers of covered packaging and plastic single-use food service ware sold into California to register, report on what they sell and, from 2027, pay producer fees.

This guide explains the law in plain English: what it is, who it applies to, what it covers, the key dates from 2022 to 2032 and the supplier data brands need to gather. It is written for brand owners and for the operations, sustainability and compliance teams who work with them.

What is California SB 54?

SB 54 is the Plastic Pollution Prevention and Packaging Producer Responsibility Act. It was signed into law on June 30, 2022, and it sits in the California Public Resources Code, starting at § 42040 et seq. CalRecycle, the state agency for recycling, administers the law.

Extended producer responsibility means the companies that put packaging on the market are responsible for it, rather than leaving it to others. Under SB 54, producers can meet many of their obligations together through a producer responsibility organization, or PRO. Circular Action Alliance (CAA) is the approved PRO for SB 54.

The law sets three targets for 2032:

• 100% of covered packaging is recyclable or compostable.
• A 65% recycling rate for single-use plastic packaging.
• A 25% source reduction of single-use plastic packaging, which in plain terms means using less material to begin with.

For most brands, the day-to-day work is data: what each packaging component is made of, how much it weighs and how many units go into California. That data mostly sits with suppliers, which is why most of this guide comes back to it.

Are you a producer under SB 54?

Producer status is the first question to settle, because everything else in SB 54 follows from it. A simple way to start is to ask three questions about each product you sell into California.

1. Who owns the brand? Start with the brand name on the pack. The company that owns that brand is the first place to look for producer status.
2. Who imports it? If the product is made abroad, find out who brings it into the country. Importers matter most when the brand owner is unclear or based elsewhere.
3. Who sells it into California? Selling into the state, in stores or online, is what brings packaging into scope. The units you sell there are also the volumes you will report.

These questions are a starting point, not a legal test. The statute’s definition of producer governs, and the details for licensees, private label and online sales are in our guide to who counts as a producer under SB 54. CalRecycle also offers a screening tool to help companies work out whether they are producers. Start from its SB 54 page to find it.

If you are still not sure, ask CAA or CalRecycle before assuming either way. Producer status is a legal question, and the answer decides whether you need to register.

What does SB 54 cover?

SB 54 covers single-use packaging and plastic single-use food service ware. It organizes covered material into covered material categories (CMCs), which group materials so that reporting and fees can follow what an item is made of. Our guide to SB 54 covered material categories explains how they work.

A packaged product usually contains several components. A jar of sauce might have a glass jar, a metal lid, a paper label and a shipping carton, and each one is a separate record in your data. Whether a particular component is covered, and in which category, depends on CalRecycle’s current definitions, so check CalRecycle for current requirements before you classify anything.

Because definitions can be updated, treat any list in an article, including this one, as a starting point and not the final word.

SB 54 timeline: key dates from 2022 to 2032

These dates reflect what CalRecycle and CAA have published at the time of writing, in November 2026. Dates can move, so confirm them against the sources at the end of this guide before you plan around them. If an item says to confirm with CalRecycle, do that first.

What supplier data do you need for SB 54?

SB 54 reporting is built from component-level packaging data. For every component of every product you sell into California, plan to collect:

• The component name, for example lid film, tray or sleeve.
• The material, stated specifically and not just as “plastic”.
• Any coating or layers added to the material.
• The weight of one unit of the component.
• A recycled content declaration.
• The units you sell into California. This is your own sales data, not the supplier’s.
• For plastic, the plastic weight and the number of plastic components per item. SB 54 requires both.

Most of this sits in supplier spec sheets, declarations and emails, not in your ERP. Our guide to the SB 54 supply report goes field by field, and you can start with our free supplier data template. If you are not sure how to ask, see how to request packaging specs from suppliers.

Four gaps show up again and again: weights missing from spec sheets, coatings that are not named, multi-material parts reported as a single line, and specs that are older than the last packaging change.

Example: one product, two component records

The table shows how a single packaged product breaks into component records. The values are illustrative, taken from the example rows in our template, and are not real supplier data.

Notice that the carton is paperboard with a plastic coating. That coating is exactly the kind of detail a one-word spec hides, and it is why we ask for coatings and layers as a separate field.

Where does SB 54 data live in your company?

Two different sources feed every record. Your own systems hold the SKUs and the units you sell into California. Your suppliers hold the material, coating, weight and recycled content for each component, usually in spec sheets, declarations of composition and email replies.

Joining the two is the real work. A purchasing team may know which supplier makes a part, a quality team may hold the spec and a sales team may hold the units, so the record often has three owners. Naming one person to own the combined list saves a lot of chasing later.

If you need help collecting this data, see our page on California SB 54 supplier data.

Who does what in SB 54 reporting?

• Brands (producers). Confirm status, register with CAA or CalRecycle, and report on the packaging they supply into California.
• Suppliers. Provide the material, coating, weight and recycled content data for the components they make or sell to you.
• CAA. The approved PRO. 2025 supply and source reduction reports were due to CAA, and CAA submits 2023 baseline data to CalRecycle for its participants.
• CalRecycle. Administers the law, and is the place to confirm definitions, requirements and status.

Suppliers hold much of the data, but the reporting is the producer’s job. That is why a clear, early request to suppliers matters.

How does SB 54 connect to SB 343?

SB 343 governs recyclability claims and labels. SB 54 uses the same recyclability determinations for producer obligations. In practice, a decision about whether a component counts as recyclable can matter in two places: what you may say on the pack, and what you owe as a producer. The comparison is covered in SB 54 vs SB 343: what each law requires.

Are there exemptions for small producers?

SB 54 includes routes for small producers and for independent producers. In both cases, producers must still register to claim that status. It does not apply automatically.

We do not state a revenue threshold here. Check CalRecycle’s SB 54 page for the current definitions and any threshold, and register to claim the status if it applies to you.

Are there legal challenges to SB 54?

Legal challenges involving SB 343 and SB 54 are pending, and the outcomes could change obligations. This guide does not predict how they will be resolved. CalRecycle’s SB 54 page is the place to check for current status.

What mistakes do brands make with SB 54?

• Assuming they are exempt without registering. Small producer and independent producer status has to be claimed through registration.
• Accepting one-word materials. “Plastic” or “paper” leaves out the coatings and layers that matter.
• Relying on old specs. A spec that predates a packaging change describes something you no longer ship.
• Waiting for fees. Fees are scheduled for 2027, but the data work has to come first, and several reporting dates fall in 2026.
• Treating labels and obligations separately. SB 343 and SB 54 use the same recyclability determinations, so keep one shared record.

What if you missed a deadline?

A passed deadline does not mean registration is closed; contact CAA. If you are not working through the PRO, contact CalRecycle. In the meantime, start collecting supplier data, because the reports you owe depend on it.

How should a brand prepare for SB 54?

Whatever your status turns out to be, the same preparation work pays off. A practical order is:

1. Confirm whether you are a producer, using CalRecycle’s screening tool and, if needed, a conversation with CAA.
2. Register with CAA or CalRecycle if you are, or to claim small producer or independent producer status.
3. List every packaging component for every SKU you sell into California.
4. Send each supplier one clear request for the fields above, as described in our guide to requesting packaging specs.
5. Record gaps instead of guessing, and follow up on a schedule.
6. Keep the source document and the date next to every value, and refresh the record when packaging changes.

Plain-English glossary

CalRecycle

The California agency that administers SB 54.

CAA (Circular Action Alliance)

The approved producer responsibility organization for SB 54.

PRO

A producer responsibility organization. Producers can join one to meet their obligations together.

EPR

Extended producer responsibility. The companies that put packaging on the market are responsible for it.

Producer

The company with obligations under the law. The statute’s definition governs.

Covered material category (CMC)

A group of materials used to organize reporting and fees. See the CMC guide.

Source reduction

In plain terms, using less packaging material to begin with.

Sources

• CalRecycle: SB 54 packaging EPR program
• Circular Action Alliance: California program page
• SB 54 statute text (Plastic Pollution Prevention and Packaging Producer Responsibility Act)

This guide is general information, not legal advice. Confirm current requirements with CalRecycle and CAA.