California EPR Guide
Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54, 2022)
Who is a “producer”?
Under SB 54, a “producer” is determined in the following order of responsibility:
- 1Brand owner of the product sold in packaging
- 2Licensee who sells under another's brand
- 3Importer of record into the US for sale in CA
- 4Person who first distributes the item in or into CA
What's covered
Covered
- ✓Single-use packaging (consumer-facing)
- ✓Plastic food service ware
- ✓B2B + B2C shipping/tertiary packaging
- ✓All component parts counted separately
Not Covered / Exempt
- ✕Packaging with 70%+ recycling rate
- ✕Small producers (<$1M CA sales)
- ✕Beverage containers under CA bottle bill
Key Deadlines
| Date | What's Due | Status |
|---|---|---|
| May 31, 2026 | 2026 Baseline Producer Report (CY 2023 data) | PASSED |
| May 31, 2026 | Annual Supply Report (CY 2025 data) + Annual Source Reduction Report | PASSED |
| Jun 15, 2026 | CAA submits draft program plan to SB 54 advisory board | URGENT |
| Aug 1, 2026 | Individual Source Reduction Plan | URGENT |
| Aug 1, 2026 | Early fee invoices issued | UPCOMING |
| Aug 14, 2026 | Public comment period on CA program plan closes | UPCOMING |
| May 31, 2027 | Next annual report (2026 data) | FUTURE |
| Jan 1, 2028 | Full program fee structure begins | FUTURE |
Fee Rates (California)
Illustrative fee rate ranges per pound (low/high scenarios). Ranges reflect the spread across CAA material categories within each group. Final rates expected Oct 2026.
Simplified groupings for estimation. Official CAA schedules have 60–95 material categories — see the downloadable rate schedule PDF below for exact rates by material type.
| Material | Rate ($/lb) |
|---|---|
| Recyclable rigid plastic (PET, HDPE, PP) | $0.11 – $0.40 |
| Non-recyclable rigid plastic (PS, PVC, mixed) | $0.17 – $1.48 |
| Recyclable flexible plastic (HDPE/LDPE film) | $0.29 – $1.00 |
| Non-recyclable flexible plastic (laminates, pouches, mixed film) | $0.57 – $1.79 |
| Paper/Fiber (corrugated) | $0.02 – $0.06 |
| Paper/Fiber (paperboard) | $0.01 – $0.08 |
| Glass bottles and jars | $0.01 – $0.03 |
| Aluminum (containers, foil) | $0.04 – $0.24 |
| Steel/tin (containers, other) | $0.02 – $0.16 |
⚠ These are estimated ranges. California has not finalized fee rates yet. Download CAA illustrative fee schedule (PDF) →
Calculate Your California Fees →Eco-Modulation Factors
Credits (reduce fees)
Not yet published by CAA; final eco-modulation expected with program plan Oct 2026
Not yet published by CAA; final eco-modulation expected with program plan Oct 2026
Not yet published by CAA; final eco-modulation expected with program plan Oct 2026
Not yet published by CAA; final eco-modulation expected with program plan Oct 2026
Maluses (increase fees)
Not yet published by CAA; final eco-modulation expected with program plan Oct 2026
Proposition 65 chemicals malus expected per SB 54; specifics not yet published
Not yet published by CAA; final eco-modulation expected with program plan Oct 2026
Source Reduction Requirements
- ✓10% plastic reduction by 2027 (from 2023 baseline)
- ✓20% reduction by 2030
- ✓25% reduction by 2032
- ✓At least 10% must come from reuse/refill or elimination
- ✓Up to 8% can come from PCR content substitution
Official Resources
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