Regulations Submitted to OAL for Approval: Supply Data and Baseline Source Reduction Reports Likely Due June 1, 2026 or Sooner

This posting is reprinted with permission from Environmental General Counsel's blog page, March 23, 2026.

Submission of Regulations to OAL

On March 19, 2026, CalRecycle submitted the draft regulations for California’s extended producer responsibility (EPR) packaging and food service ware program (SB 54) to the Office of Administrative Law (OAL) for approval – requesting an early effective date.  OAL has thirty working days to approve the regulations. 

Due Date for Submission of Reports

After approval by OAL, under the last working draft of the regulations (and based on Circular Action Alliance announcements), supply data and 2023 baseline data for source reduction purposes will be due no later than thirty days after the effective date of the regulations – meaning they would be due no later than June 1, 2026 and possibly earlier (if OAL approves before May 1, 2026).

Meanwhile, to harmonize reporting requirements, CAA has established their own May 31, 2026 deadline for annual supply data reporting across California, Oregon, Colorado, Maryland, Minnesota, and Washington – many Canadian provinces also have May 31 reporting deadlines.

Producers in Oregon should seek legal advice about the status of the litigation which has stayed enforcement of the state's EPR program as to members of the National Association of Wholesaler-Distributors -- and the significance, if any, for their own reporting requirements.

What to Do

Companies should prepare for compliance by:

·       evaluating their status as a producer,

·       registering with CAA,

·       evaluating what specific covered materials they are responsible for as a producer,

·       collecting and reporting supply data – and,

·      for plastic covered materials, submitting 2023 baseline source reduction reports

Conclusions

With harmonized reporting requirements across multi-jurisdictions (the U.S. and Canada), producers who are only now collecting the necessary information should begin to prepare for compliance.