CAA Publishes "Ilustrative Fees" for California's EPR Program

By Adrien Thein-Sandler, Senior Policy Advisor

Producers obligated under California’s extended producer responsibility (EPR) program for packaging and food service ware have a new fee-estimate tool as they plan for program implementation in 2027.

Circular Action Alliance (CAA) published its first version of “California Illustrative Fees” on May 1st, 2026, the same day California’s implementing regulations became effective (more on the final regulations in a forthcoming article).

The California Illustrative Fees are CAA’s good-faith, non-binding fee rate ranges intended to help producers form budgets and evaluate source reduction, reuse, and refill strategies. CAA based these ranges on current assumptions in the SB 54 Needs Assessment and the funding obligations required by statute. CAA still needs to analyze producers’ reporting data due May 31, 2026, before it can finalize fee rates in its program plan submission in October 2026.

While the Illustrative Fee numbers will most likely change as CAA develops more complete supply-side data, this first version is still useful.

First, producers get an order-of-magnitude understanding for anticipated base material fees. For example, most base fees in the Plastic material categories are an order of magnitude higher than most of the Paper/Fiber categories (although results are more mixed in the “high” fee scenario). See our previous overview of producer fees and our 2025 update piece for helpful background.

Second, producers see a preview of how the extra fees for plastic materials work. California’s EPR law requires producers to fund a $500 million per year Plastic Pollution Mitigation Fund assessed both by weight and number of a producer’s plastic components. CAA’s Illustrative Fees apportion this extra fee more dependently on the weight-based metric compared to the component-based metric, potentially informing how producers evaluate the fee implications of material design changes. An additional 4 cents (low scenario) or 10 cents (high scenario) per pound of plastic, subject to change in the final program plan, will cover investment into reuse and refill systems as part of the mandatory plastic source reduction measures CAA must achieve. See our previous source reduction summary for background.

These additional fee factors for plastic can be significant depending on the covered material category and how plastic is incorporated. For example, producers may pay just a few cents per pound for cardboard, but if the cardboard contains a plastic component (such as a laminate or seal), their fee could rise significantly depending on the weight of that plastic component since the fee per pound of plastic is often an order of magnitude greater than the base fee of easily-recycled materials like cardboard, paperboard, and glass.

California’s eco-modulated fee incentive scheme will likely present further opportunities to optimize fees based on packaging design practices beyond the plastic vs. non-plastic dynamic discussed above. Eco-modulation generally phases in over time, so California’s eco-modulated factors are not all reflected in the Illustrative Fees. We continue to monitor this issue across the U.S. EPR states because understanding the tapestry of incentives nationwide will impact producers’ long-term strategy.

EPR Group guides producers’ obligation assessments, reporting, and strategic planning to comply with U.S. and Canadian EPR laws accurately and optimally.