Key takeaway
What This Development Means
California’s proposed permanent SB 54 regulations clarify producer duties and accelerate the shift to recyclable and compostable packaging. With enforcement set to scale from 2026, supply chain actors must prepare for sweeping compliance, reporting, and labelling changes. Public consultation closes on 7 October 2025.
Who qualifies as a “producer” under California’s SB 54 regulations?
A “producer” is generally the brand owner, manufacturer, or importer of goods sold in California that use covered materials. The definition prioritises control over trademarks and market access to ensure accountability aligns with decision-making authority.
What materials are exempt from SB 54 compliance?
Reusable, refillable, or FDA-mandated packaging may be excluded from regulation. Exemptions must be documented and justified, especially where federal food safety standards limit alternatives.
Source basis: https://eping.wto.org/en/Search/Index?viewData=%20G/TBT/N/USA/2088/Rev.1
New rules clarify responsibilities under SB 54, requiring all single-use packaging to be recyclable or compostable by 2032.
California has unveiled its proposed permanent regulations for the Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54), marking a critical regulatory milestone for packaging producers and the broader manufacturing ecosystem. Issued by the Department of Resources Recycling and Recovery (CalRecycle), the rules spell out how producers must comply with extended producer responsibility (EPR) mandates under SB 54 and associated laws like AB 1201.
The regulations impose new compliance obligations on producers of single-use packaging and plastic food service ware sold in California, regardless of where these materials are made. By 2032, all such materials must be recyclable or compostable, with progressive recycling rate targets and mandatory source reduction beginning as early as 2026.
Clarity For Producers And Retailers
The regulations define who qualifies as a “producer,” prioritising brand owners, manufacturers, and importers with control over trademarks used in the state. This clear hierarchy resolves long-standing ambiguity in the supply chain and ensures that accountability aligns with market power.
Producers must register with CalRecycle, report annually on the types and volumes of packaging materials sold, and demonstrate how they meet design-for-recycling and source reduction goals. Companies may join a Producer Responsibility Organization (PRO) to fulfil these obligations collectively or submit an independent compliance plan.
Compostable Labelling Now Regulated
AB 1201’s integration into the SB 54 framework introduces strict certification standards for compostable labelling. Products must now meet ISO-based technical standards for biodegradation and disintegration and may not contain per- and polyfluoroalkyl substances (PFAS) to qualify.
This move aims to eliminate greenwashing and improve the integrity of environmental claims, offering recyclers and composters greater certainty on material inputs.
Implications Across The Supply Chain
The rules will reverberate beyond manufacturers. Retailers, wholesalers, local jurisdictions, and recycling operators will face changes to their roles in material collection and infrastructure planning. CalRecycle estimates non-discretionary costs for local governments will exceed $18 million annually—but these will be reimbursed by producers or PROs.
Stakeholders should also note that CalRecycle may investigate claims of exemption or non-coverage, particularly where producers assert that materials are reusable, refillable, or fall under FDA/USDA packaging exemptions.
Public Input And Next Steps
A hybrid public hearing will take place on 7 October 2025 in Sacramento and via Zoom. The written comment period runs through 7 October 2025. CalRecycle encourages industry professionals, especially those involved in packaging design, compliance, or sustainability strategy, to engage with the process.
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