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California EPR Guide

Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54, 2022)

Active — Regulations Finalized, Reporting Due
PRO
Circular Action Alliance
Agency
CalRecycle
Exemption
Under $1M gross sales in California (no volume threshold)
Fees
Preliminary 2027 fee schedule published Oct 1, 2026 — rates non-binding pending CalRecycle approval of the program plan. Fees begin January 2027: base fees + reuse investment fee ($0.03/lb plastic) + PPMF ($0.26/unit plastic weight, $0.001/component).
Material Categories
95
Penalties
Up to $50,000/day for general entities; up to $25,000/day for small entities per PRC §42081

Who is a “producer”?

Under SB 54, a “producer” is determined in the following order of responsibility:

  1. 1Brand owner of the product sold in packaging
  2. 2Licensee who sells under another's brand
  3. 3Importer of record into the US for sale in CA
  4. 4Person who first distributes the item in or into CA

What's covered

Covered

  • ✓Single-use packaging
  • ✓Plastic food service ware
  • ✓B2B transport/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
  • ✕Packaging not collected residentially that is recycled at a responsible end market at a 65% (70% after 2027) rate — PRC §42041(e)(2)(H)

Fee Rates (California)

Preliminary 2027 base fee rates per pound from CAA's Oct 1, 2026 schedule — non-binding pending CalRecycle approval of the program plan. Rates shown combine the total base fee with the $0.03/lb reuse investment fee and $0.26/lb PPMF weight fee for plastic; the $0.001 per-component PPMF charge is not included.

Simplified groupings for estimation. The official CAA schedule has 95 material categories — see the downloadable rate schedule PDF below for exact rates by material type.

MaterialRate ($/lb)
Rigid PET plastic (#1)$0.15 – $0.19
Non-recyclable rigid plastic (PVC, mixed)$0.26
Flexible plastic film (PET/LDPE/PP)$0.27 – $0.30
Non-recyclable flexible plastic (laminates, pouches, mixed film)$0.27
Paper/Fiber (corrugated cardboard)$0.03
Paper/Fiber (paperboard)$0.02 – $0.05
Glass bottles and jars$0.02
Aluminum (containers, foil)$0.01 – $0.17
Steel/tin (containers, other)$0.02 – $0.16

⚠ California rates are preliminary — final fees may change. Download CAA 2027 fee schedule (PDF) →

Calculate Your California Fees →

Eco-Modulation Factors

Credits (reduce fees)

High recycling rate-5% (published)

CAA 2027 schedule: -5% for materials with a recycling rate higher than their 2028 target. Automatically applied.

Maluses (increase fees)

Not recyclable or compostable+5% (published)

CAA 2027 schedule: +5% for materials that are both non-recyclable and not compostable. Automatically applied.

Prop 65 chemicalsNot in 2027 schedule

Not included in CAA's preliminary 2027 fee schedule. SB 54 authorizes malus factors — watch final program plan.

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

Key Deadlines

DateWhat's DueStatus
May 31, 20262026 Baseline Producer Report (CY 2023 data)PASSED
May 31, 2026Annual Supply Report (CY 2025 data) + Annual Source Reduction ReportPASSED
Jun 15, 2026CAA submits draft program plan to SB 54 advisory boardPASSED
Aug 1, 2026Individual Source Reduction PlanPASSED
Aug 1, 2026Early fee invoices issuedPASSED
Aug 14, 2026Public comment period on CA program plan closesPASSED
Oct 31, 2026Final 2027 fee schedule expected by end of OctoberUPCOMING
May 31, 2027Next annual report (2026 data)FUTURE
Jan 1, 2028Full program fee structure beginsFUTURE

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