Key Takeaways
What Happened? Despite delayed implementing regulations, Circular Action Alliance (CAA), the producer responsibility organization (PRO) responsible for administering California’s packaging extended producer responsibility (EPR) program under SB 54, has set compliance deadlines for SB 54’s source reduction reporting requirements. In addition to annual supply reporting, producers must also comply with three separate source reduction reporting obligations, including the requirement to submit individual source reduction plans, which CAA has stated will be due no later than August 1, 2026, with the most up-to-date information on the corresponding deadlines described in detail below.
Who is Impacted? Producers of single-use packaging or plastic single-use food service ware with reporting obligations in California.
What Should Producers Consider Doing in Response? With a number of deadlines fast approaching, producers should be preparing to meet upcoming SB 54 reporting obligations. This includes compiling relevant packaging and plastic component data and reviewing available reporting templates and guidance to meet source reduction reporting obligations. Producers should closely monitor updates from the California Department of Resources Recycling and Recovery (CalRecycle) and CAA, as deadlines may change and additional reporting templates and guidance may be released before and/or after CalRecycle’s SB 54 implementing regulations become final.
Source Reporting Requirements
SB 54, like other state packaging EPR laws, imposes registration, reporting, and payment obligations for producers of certain single-use packaging and food service ware. However, unlike the other six states with packaging EPR laws, SB 54 imposes several deadlines by which packaging must be recyclable and meet certain recycling metrics, and by which certain source reduction goals must be achieved. For example, producers must ensure that all covered materials sold, distributed, or imported into the state must be “recyclable” or eligible to be labeled “compostable” by January 1, 2032. Additionally, producers must ensure that plastic covered material achieves a recycling rate of at least 30% on and after January 1, 2028. This rate increases over time, and must be at least 65% by January 1, 2032.
Source Reduction. In addition to the annual supply reporting, the statute also requires CAA to develop a plan to meet the source reduction milestones described below. While the statute requires CAA to develop a plan to achieve these milestones, the statute requires the PRO to “establish enforceable agreements with each of its approved plan participants to implement” these requirements. PRC § (42057(a)(1)). CAA must report source reduction data to CalRecycle that is disaggregated by each producer, PRC § 42057(c). To comply with this requirement, CAA is collecting source reduction data from producers as part of the annual supply reports. CAA has set May 31, 2026 as the due date for these annual reports.
PRC § 42057(a) requires CAA to meet the following source reduction targets:
- January 1, 2027 – 10% source reduction for plastic covered material sold, offered for sale, or distributed in the state by participant producers, with no less than 2% reduced by shifting to reusable or refillable packaging.
- January 1, 2030 – 20% source reduction for plastic covered material sold, offered for sale, or distributed in the state by participant producers, with no less than 4% reduced by shifting to reusable or refillable packaging.
- January 1, 2032 – 25% source reduction for plastic covered material sold, offered for sale, or distributed in the state by participant producers, measured both by packaging weight and by number of plastic components, with no less than 10% reduced through reuse, refill, or elimination.
While many of these requirements are on the PRO level, the statute requires producers to submit data to CAA to support their achievement of these milestones. CAA has already issued its Individual Source Reduction Plan guidance, available to producers that have registered with CAA, and has indicated that a forthcoming addendum will address annual source reduction reporting.
Key Near-Term Reporting Requirements and Deadlines
Annual Supply Reports (Including Source Reduction Data). As of the date of publication of this alert, CAA has set a deadline of May 31, 2026 for producers to submit annual producer supply reports. These reports will include information on the amount of packaging supplied to California in 2025, as well as certain source reduction data. CAA will rely on this data as it prepares to submit its upcoming annual report to CalRecycle. CAA’s expected May 31, 2026, deadline may change further as CalRecycle continues to work toward finalizing the implementing regulations for SB 54.
Source Reduction Baseline Reports. Within 30 days after the effective date of the final regulations, producers will be required to submit a baseline report containing 2023 data. This baseline report will serve as the reference point for measuring future progress in source reduction. Because the adoption of CalRecycle’s final regulations triggers the deadline, the exact due date remains subject to change, but we expect CalRecycle to finalize the regulations in the next several weeks. CAA reports that many producers have already submitted their baseline reports. CalRecycle has stated that they anticipate the regulations to be finalized on May 1, so producers should prepare to submit their baseline reports by May 31.
Individual Source Reduction Plans. SB 54 requires producers to submit individual source reduction plans to CAA. These plans require producers to forecast their expected net source reduction and source reduction activities over the program years and will help CAA determine whether the statewide source reduction milestones—including SB 54’s 25% source reduction target by January 1, 2032—will be met. In March, CAA released its Individual Source Reduction Plan Guidance. CAA has not yet published the specific deadline for producers to submit their individual source reduction plans, but states in its guidance that it will do so within 30 days after the effective date of the final regulations and that the individual source reduction plans will be due no later than August 1, 2026.
CAA has substantially delayed implementation of SB 54 to accommodate repeated revisions to CalRecycle’s implementing regulations. In March 2025, California Governor Gavin Newsom directed CalRecycle to revise its draft regulations to address concerns over costs to small businesses. After proposing updated draft regulations on January 9, 2026, CalRecycle again withdrew the regulations to make targeted revisions with a particular focus on packaging for food and agricultural commodities. CalRecycle re-published the regulations on January 29, 2026, subject to a 15-day public comment period, and CalRecycle has sent the draft regulations to the California Office of Administrative Law for review and finalization. Beveridge & Diamond anticipates that the regulations will be finalized in the next several weeks and recommends that producers prepare to submit their annual supply reports by CAA’s May 31, 2026, deadline.
CalRecycle’s draft SB 54 regulations require CAA to submit its source reduction baseline report to CalRecycle by July 1, 2026. 14 CCR § 18980.9(a) (draft). Further, CAA has stated that it intends to submit its annual source reduction and supply reports to CalRecycle beginning in 2026. Because CAA’s annual and baseline reporting obligations rely on data from producers, we expect CAA to adhere to the May 31, 2026, producer report deadline and for program implementation to occur quickly once the regulations are finalized.
Penalties for Non-Compliance
Given the fast-approaching deadlines for statewide source reduction, we expect CAA and CalRecycle to implement and enforce these requirements quickly. Enforcement may begin slowly with notices of non-compliance; however, SB 54 authorizes CalRecycle to impose administrative civil penalties up to $50,000 per day per violation. Additionally, CAA’s producer policies impose penalties for non-compliance. CAA’s reporting policy and payment policy impose late charges for failure to report timely and to pay fees, respectively. Under the payment policy’s late payment charge, producers are assessed interest, compounded monthly, on the portion of the outstanding balance that remains unpaid after the payment due date.
