SB 54 fees: what to expect from 2027

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

SB 54 producer fees are scheduled to begin in 2027. CAA sets the fees, and they are based on the material and recyclability of the packaging you supply into California.

No California fee schedule is quoted in this guide, because the rates are CAA’s to publish. What we can do is explain what drives fees and show how a per-pound schedule works using Oregon as an example. This guide is part of our California SB 54 guide.

When do SB 54 fees start?

Producer fees are scheduled to begin in 2027. Check CAA’s California page and CalRecycle for the current schedule, since dates can move.

Who sets the fees?

CAA, the approved PRO for SB 54, sets the fees. Producers that are not in the PRO should check with CalRecycle for current requirements.

What are SB 54 fees based on?

Fees are based on material and recyclability. In practice that means the data you collect from suppliers, namely the material, any coating or layers, the weight and the units you sell, decides which fee line a component falls into and how much it costs. Recyclability determinations also connect to SB 343, as explained in SB 54 vs SB 343.

What do per-pound fees look like? An Oregon example

Oregon already publishes per-pound fees by material category. These are Oregon’s 2026 rates, shown only to illustrate the mechanics. They are not California rates.

Oregon example, not California rates. Do not use these figures to estimate an SB 54 bill.

The coated version costs six times as much per pound. As a purely hypothetical illustration, 1,000 pounds of uncoated paperboard at 8 cents per pound is $80, and 1,000 pounds of plastic-coated paperboard at 48 cents per pound is $480. The only difference between the two lines is whether a supplier spec mentions a plastic coating.

Which data points move your fee?

• Material. It decides the category and so the rate. See SB 54 covered material categories.
• Coating or layers. They can move a component to a different line.
• Weight per unit. In a per-pound model, every error in weight carries through to the fee.
• Units sold into California. They turn unit weights into totals.
• Recyclability. It is one of the two things fees are based on, so recyclability determinations matter.

How do fees relate to the 2032 targets?

SB 54 sets targets for 2032: 100% of covered packaging recyclable or compostable, a 65% recycling rate for single-use plastic packaging and 25% source reduction of single-use plastic packaging. Fees are based on material and recyclability, which are the same properties those targets are about. How CAA designs the schedule is for CAA to publish, so check its California page rather than relying on assumptions.

What questions should finance and packaging teams ask now?

• Which SKUs do we sell into California, and in what volumes?
• Do we have a current weight for every component?
• Which components have a coating or several layers?
• Which suppliers have not yet sent specs?
• Where would a change of material change the cost?
• Who owns the answer to each question?

What are common misunderstandings about SB 54 fees?

• “Oregon’s rates are California’s rates.” They are not. The Oregon figures here only illustrate how per-pound schedules work.
• “Weight is all that matters.” Fees are based on material and recyclability, so material and coatings matter at least as much.
• “We can estimate later.” Estimates made late tend to be the ones that are wrong. Collect the data from suppliers first.

How can you prepare before fees begin?

1. Build a component-level record for each SKU you sell into California. The supplier data template is a starting point.
2. Collect material, coating or layers and weight from every supplier, as described in SB 54 supply report data.
3. Record gaps and chase them, instead of estimating.
4. Pull your California unit sales by SKU.
5. Watch CAA’s California page and CalRecycle for the fee schedule.

Related guides

• California SB 54 explained: a plain-English guide for brands
• SB 54 covered material categories, explained
• SB 54 vs SB 343: what each law requires

Sources

• Circular Action Alliance: California program page
• CalRecycle: SB 54 packaging EPR program
• CAA Oregon 2026 producer fee schedule (Internet Archive copy)

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