How to File the California Annual Supply Report (SB 54)

The California Annual Supply Report is the core EPR filing under SB 54. It determines your fee basis — the total packaging weight you sell into California, broken down by material type. This guide walks you through every step, from understanding what goes into the report to submitting it through the CAA Producer Portal.

Step 1: Confirm you are obligated

You must file if you are a “producer” under SB 54 — meaning you are the brand owner, licensee, importer of record, or first distributor of a packaged product sold into California — and your gross sales in California exceed $1 million. There is no volume threshold; revenue alone determines exemption.

If you sell into CA but have less than $1M in CA revenue, you are exempt from reporting. However, if you expect to cross $1M in the future, start tracking now — your baseline year matters.

Not sure if you are covered? Check in 60 seconds with our free coverage checker.

Step 2: Understand what is covered

California has the broadest scope of any EPR state. Covered materials include:

• Single-use packaging — all consumer-facing packaging (bottles, tubs, trays, bags, wraps, inserts)
• Plastic food service ware — plates, bowls, cups, utensils, straws, stirrers
• B2B and B2C shipping/tertiary packaging — corrugated shippers, stretch wrap, pallet strapping, void fill
• Component parts counted separately — every cap, label, film, and insert is a separate line item

Key exclusions: packaging with a 65%+ recycling rate, small producers (under $1M CA sales), and beverage containers already covered under the California bottle bill.

Step 3: Map your packaging to CalRecycle CMCs

CalRecycle maintains a list of Covered Material Categories (CMCs) — approximately 95 material types. Every component of every product you sell into CA must be assigned to one of these CMCs. The major groups are:

Critical: each component is reported separately. A product with a PET bottle (22g), HDPE cap (3g), paper label (1g), film shrink wrap (2g), corrugated shipper (180g), and tissue insert (3g) is six line items, not one.

Step 4: Calculate weight by material

For each component of each SKU, you need:

1. Weight per unit — from supplier spec sheets (most accurate), physical sample weighing, or packaging spend proxy
2. Units sold nationally — from your sales/ERP system for calendar year 2025
3. California revenue percentage — from your accounting system

Need help estimating weights? See our weight estimation guide or use the calculator.

Step 5: Register and submit through CAA

All California EPR reports are filed through the Circular Action Alliance Producer Portal. If you have not already registered:

1. Go to circularactionalliance.org/producer-resource-center
2. Create a producer account with your business details
3. Select California as a covered state
4. Complete the Annual Supply Report form — enter weight by CMC in pounds
5. Include your revenue allocation methodology (how you determined the CA percentage)
6. Submit before May 31, 2026

The CAA portal calculates your fees from the submitted data × the published fee schedule. You do not calculate fees yourself — you provide weight data, and CAA generates the invoice.

Step 6: Three separate filings due May 31, 2026

California has three distinct reports due on the same date. The Annual Supply Report is just one of them:

Common mistakes

• Reporting product weight instead of packaging weight. Only the packaging counts — not the contents.
• Bundling components. Each material component is a separate line. A bottle, cap, label, and film wrap are four entries, not one.
• Using national totals. You must allocate to CA based on your CA revenue percentage.
• Classifying everything as non-recyclable. PET, HDPE, and PP containers are recyclable and cost 3–5x less per pound. Correct classification saves real money.
• Forgetting tertiary packaging. Shipping boxes, stretch wrap, and pallet strapping are covered in California. If you ship product, you have tertiary weight to report.
• Waiting for perfect data. File with best-available estimates. Late filing risks $50,000/day penalties.

Eco-modulation (anticipated)

California's eco-modulation factors have not yet been published. The May 2026 illustrative fee schedule does not include eco-modulation adjustments — it uses a 4-element fee structure (Total Base Fee + Reuse Investment Fee + PPMF Weight-Based Fee + PPMF Component-Based Fee). CAA is expected to publish eco-modulation details with the final program plan in October 2026.

The following factors are anticipatedbased on SB 54 statutory requirements and CAA's other state programs, but are not yet confirmed:

Specific ranges will be published by CAA with the final program plan. See strategies to reduce your fees →

Filing checklist