CAA’s California Program Plan and SB 54 Implementation Update, June 2026

SB 54, California’s extended producer responsibility (EPR) program for certain packaging and food service ware materials, is finally up and running and quickly moving forward. In the past two months, CalRecycle’s regulations were approved and finalized, producers submitted their first supply reports to Circular Action Alliance (CAA), and CAA published its draft California Program Plan. Next, producers will submit their Individual Source Reduction (ISR) Plans by August 1 (click here to read more about ISR requirements).

The California Program Plan details CAA’s strategy to implement SB 54 and is open for public comment until August 14. CAA must achieve statutory and regulatory requirements, but to a large degree CAA can decide how to achieve them. 

For example, SB 54 requires CAA to meet plastic source reduction benchmarks relative to a 2023 baseline and within certain proportions of reduction methods (e.g., among shifts to reuse/refill/elimination, incorporating PCR content, replacing plastic with non-plastic components, rightsizing, lightweighting, etc.). But since this statutory requirement falls on CAA, not on producers, CAA ultimately decides how to incentivize producers to source reduce their plastic. CAA’s Program Plan lays out its approach to (1) use fee bonuses and maluses depending on how successfully a producer source reduces compared to other producers; (2) develop an Administered Exchange approach, which is essentially a cap and trade system for plastic covered materials; and (3) invest in developing reuse and refill systems to overcome the collective action problem for kickstarting these systems.  

As another example, consider SB 54’s looming 2032 deadline for all covered materials to be either recyclable or eligible to be labeled compostable, as those terms are rigidly defined in SB 54. CAA needs to balance this requirement with its recycling infrastructure upgrade strategy by choosing which currently non-recyclable materials to invest into and which to phase out. Investing into non-recyclable materials means CAA will expand the recycling infrastructure for those materials in order to phase them into compliance (e.g., PET thermoforms). Phasing a material into compliance means achieving a collection rate covering at least 60% of the state’s population and material-defined sortation serving at least 60% of the state’s recycling programs, among other requirements. Phasing a material out means not investing in its waste management capacity, whereupon it will become prohibited in 2032 due to remaining non-recyclable, as defined by SB 54. By that time, CAA intends to have incentivized producers to shift to other “phased in” or already compliant material alternatives. Critically for many industries, CAA aims to phase in most types of flexible and film plastics, although certain specific resins will be phased out (e.g., non-polyolefin mono-material plastic film). 

Notably, CAA has proposed “unique challenge exemptions” for 56 covered material categories. If CalRecycle approves the exemptions, producers may continue to use those covered materials for a specified period (likely two to five years), regardless of whether those materials comply with SB 54’s requirements for recyclability, recycling rates, source reduction, and more. CAA’s proposed exemptions would give CAA and producers extra time in which to phase in certain covered materials and phase out others, given California’s especially crunched implementation timeline.

Expert guidance helps producers to come into compliance from a blank slate, improve upon their past reporting and current capabilities, or plan a year-over-year compliance strategy for California’s unique requirements as well as the six other U.S. EPR programs enacted so far.