California SB 54 packaging compliance for consumer brands.

What SB 54 is

The Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54) was enacted in 2022 and is administered by CalRecycle. It is the most ambitious U.S. packaging EPR law because it pairs producer financing with performance requirements: reducing single-use plastic, raising recycling rates and making covered material recyclable or compostable.

Who is a producer: the hierarchy

SB 54 defines “producer” in Public Resources Code § 42041(w) using a hierarchy. At a high level, the obligation generally sits with the brand owner of the product that uses the packaging. Where no brand owner can be identified in the way the statute describes, responsibility can move to others in the chain, such as a licensee or the person who imports or first distributes the product into California. The statute also describes how specific situations, such as on-site agricultural packaging, are treated.

For most branded CPG companies, the practical starting assumption is that the brand owner should evaluate its obligation, even when a co-packer manufactures the product. Private label, licensed brands and imported goods need a closer reading.

Covered material, at a high level

Covered material includes single-use packaging and plastic single-use food service ware supplied in or into California, subject to the definitions and exclusions in the statute and regulations. CalRecycle maintains a Covered Material Categories List, which groups materials and records recyclability and compostability determinations. Reporting is organized around those categories, so packaging data has to be captured at a level that maps cleanly to them.

Exclusions and exemptions, at a high level

• Small producers. CalRecycle describes a small producer exemption for producers with gross annual sales under $1 million, applied for through PEPRS (14 CCR § 18980.5.2). CalRecycle notes small producers still need to plan for covered material to be recyclable or compostable by 2032.
• De minimis components. Certain single-use packaging components meeting criteria in 14 CCR § 18980.2.2(b) are not covered material. Single-use plastic food service ware cannot be de minimis.
• Food and agricultural packaging. Where a conflict with federal requirements is identified, producers must submit a complete exclusion notice to CalRecycle (14 CCR § 18980.2(a)(2)).
• Recycling-rate exclusion. Subject to CalRecycle approval, items that achieve specified recycling rates outside curbside collection may be excluded (14 CCR § 18980.2.3).
• Covered material exemptions. Some covered material may be exempted from certain requirements for unique compliance challenges or health and safety reasons, subject to approval (14 CCR § 18980.2.4).

Each exclusion or exemption has its own process. Some require an application or notice; none should be assumed.

Compliance pathways: PRO participation or individual compliance

CalRecycle describes three pathways: apply to participate in the PRO plan, submit an independent producer application, or obtain a small producer exemption. For most consumer brands, PRO participation through CAA is the practical route. Individual compliance requires a CalRecycle-approved plan under 14 CCR § 18980.7 showing the producer meets recycling rate and source-reduction requirements for its covered material, which is a substantial undertaking.

Reporting can be handled through the PRO or, for PRO participants who opt out of PRO reporting, self-reported. Either way, the underlying packaging data has to exist.

Source reduction and performance targets

CalRecycle's producer guidance lists these statewide targets, measured as of January 1 of each year:

Source reduction has direct data implications. CalRecycle published Source Reduction Reporting Guidance in August 2026. Demonstrating reduction requires a baseline, which means producers need accurate, versioned records of plastic packaging weights and units over time. Packaging redesign decisions also become compliance decisions.

A practical reporting workflow

1. Confirm which brands and SKUs are supplied into California, including through distributors and e-commerce.
2. Screen producer status for each brand under the hierarchy, and evaluate exemptions or exclusions that may apply.
3. Build a component-level packaging record for each SKU: material, format and weight.
4. Map components to CalRecycle's Covered Material Categories.
5. Allocate quantities to California using sales or shipment data for the relevant period.
6. Prepare outputs in the format required by CAA or PEPRS, and retain evidence.
7. Track plastic weights over time to support source-reduction reporting.

Common operational gaps

• No component-level weights for closures, labels, films and secondary packaging.
• Unclear California volumes because distributors resell across state lines.
• Plastic resin types missing from supplier specs, which matters for category mapping.
• No historical baseline for source reduction.
• Co-packer or importer relationships that blur who the producer is.

What your team should prepare

• A SKU list for products sold or shipped into California, with brand ownership noted.
• Units sold or shipped into California by SKU for the most recent full year.
• Packaging specifications by component, including plastic resin types where available.
• A list of co-packers, importers and distributors involved in California supply.
• Any prior communications with CAA or CalRecycle, including PEPRS registration status.

How CertaRelay helps

• Screen producer status and potential exemptions under SB 54, flagging questions for counsel.
• Build and maintain your component-level packaging data, mapped to CalRecycle categories.
• Prepare filing-ready outputs and support PRO registration and submissions.
• Track plastic packaging over time to support source-reduction reporting and redesign decisions.
• Forecast fee exposure as CAA publishes California rates. See EPR fees.