Under SB 54, any brand that sells products in covered packaging into California must register, report, submit a source reduction plan, and — starting 2027 — pay PRO fees. Headquarters location does not matter.
California's SB 54 (Plastic Pollution Prevention and Packaging Producer Responsibility Act) is the broadest EPR packaging law in the U.S. It requires three distinct operational steps, each with independent compliance timelines.
Join a CalRecycle-approved Producer Responsibility Organization (PRO). Deadline passed — backfill registration now to avoid compounding penalties.
Report all covered packaging by type, weight, and recyclability category, meeting CalRecycle's data-quality standards. Your Individual Source Reduction (ISR) Plan was due August 3, 2026 — next up is January 1, 2027, when the 10% source reduction target becomes enforceable.
Beginning January 1, 2027, covered producers must pay annual fees to their PRO based on material volume and recyclability. Eco-modulation credits available for sustainable designs.
You are likely covered if you sell or distribute products in California using any of the following:
A small producer exemption exists — for producers below $1 million in California sales — but it is not automatic: it must be applied for through CalRecycle's PEPRS system and re-tested each year.
Below the thresholds is a position, not a formality. An exemption does not assert itself — where nothing on file states that a producer qualifies, an open account can read the same as an unmet obligation.
How the Small Producer Exemption worksThe California EPR Compliance Blueprint maps your applicable obligations under SB 54 — registration status, reporting deadlines, fee estimates, eco-modulation opportunities, and a step-by-step remediation plan. Fixed price. No billable hours.
From $1,200, credited toward Managed · Managed from $12,000/year, all states
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