California SB 54 update

CAA's California SB 54 program plan: what brands need to know.

Circular Action Alliance's revised plan is under CalRecycle review. Here is the timeline, what changed and what it means for your packaging data and fees.

By CertaRelayLast updated: Requirements may change. Verify current obligations with the applicable agency, PRO or qualified counsel.

Short answer: Circular Action Alliance (CAA) submitted its revised SB 54 producer responsibility plan to CalRecycle on October 13, 2026. CalRecycle has 75 days to approve, disapprove or conditionally approve it, which points to a decision around late December 2026. Public comments to CalRecycle are due November 13, 2026. The plan sets out how California's program will be funded, including the fee setting methodology producers will pay under, so brands selling into California should be budgeting and building their packaging data now.

Where the plan stands

Sources: CalRecycle and Circular Action Alliance. The late December date is our calculation from the 75 day review period; CalRecycle has not published a decision date.
DateMilestone
June 15, 2026CAA released its draft California program plan for public comment.
August 14, 2026CAA's comment period closed. CAA reports more than 2,400 comments.
October 13, 2026CAA submitted the revised plan; CalRecycle received it the same day.
November 6, 2026SB 54 Advisory Board meeting.
November 13, 2026Deadline for public comments to CalRecycle.
About December 27, 2026End of CalRecycle's 75 day review period.
January 1, 2027CAA's implementation target, and CalRecycle's deadline to publish an updated Covered Material Categories List.

What changed in the revised plan

CAA says the revised plan builds on the draft it shared in June and responds to comments from local governments, trade associations, NGOs, tribal representatives, producers and the advisory board. According to CAA, the revisions touch environmental justice, reimbursement to local jurisdictions, materials strategy, responsible end markets, budget development and fee setting. The budget and fee chapters were expanded with more detail on planned investments, expected costs and how producer funding supports implementation over time.

What CalRecycle can decide

Under the SB 54 regulations, CalRecycle reviews the plan for compliance and can approve it, disapprove it or approve it with conditions. A conditional approval or disapproval would mean further revisions before the program's financial and operational details are settled. Either way, producer obligations under SB 54 already apply: the permanent regulations took effect in May 2026.

What it means for brands

  • Fees are getting closer. The plan describes the methodology behind producer fees. Once a plan is approved, finance teams will want a forecast built on real packaging weights, not estimates.
  • Category mapping matters. Fees and reporting are organized around CalRecycle's Covered Material Categories, with an updated list due by January 1, 2027. Component data that cannot be mapped to a category is a common blocker in packaging records.
  • Source reduction needs a baseline. SB 54's plastic reduction targets start in 2027. A defensible baseline requires versioned plastic weights and units by SKU.
  • Registration is not the finish line. If you registered with CAA, annual reporting and fees still follow. See what CAA registration does and does not complete.

What to do now

  1. Confirm which of your brands and SKUs are supplied into California, including through distributors and online channels.
  2. Confirm your producer status and registration in CalRecycle's PEPRS portal and with CAA.
  3. Build a component level packaging record: material, format and weight for every part of every SKU.
  4. Map components to the current Covered Material Categories List, and plan to recheck when the January 2027 update is published.
  5. Allocate California units by SKU so a fee forecast can be built as soon as rates are known.
  6. If you want to comment on the plan, email CalRecycle at packaging@calrecycle.ca.gov with the subject line “PRO Plan Comments” by November 13, 2026.

How CertaRelay helps

  • Build and maintain your component level packaging record, mapped to CalRecycle's categories.
  • Collect missing weights and materials from suppliers and contract manufacturers.
  • Forecast California fee exposure as rates are published. See EPR fees.
  • Track deadlines and prepare reports for your approval.

Frequently asked questions

When will CalRecycle decide on CAA's SB 54 plan?

CalRecycle received the plan on October 13, 2026 and has 75 days to review it, which runs to about December 27, 2026. CalRecycle has not announced a specific decision date.

Can brands comment on the plan?

Yes. CalRecycle is accepting public comments through November 13, 2026 at packaging@calrecycle.ca.gov with the subject line “PRO Plan Comments.”

Does the plan set my company's fee?

The plan describes the budget and the fee setting methodology. Your actual fee depends on the rates CAA publishes and the weight and material of the covered packaging you supply into California, which is why accurate component data matters.

Do I need to act before the plan is approved?

Yes. SB 54's permanent regulations have applied since May 2026. Registration, reporting and data preparation do not wait for plan approval, and reporting depends on packaging data most brands still need to assemble.

Keep going

Official sources

Next step

Get ready for California fees.

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