California SB 54 already applies to your brand.Registration and reporting are live now. Fees begin January 1, 2027.
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.
Complimentary. No commitment.
What the California EPR law (SB 54) requires from your brand
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. EPR California, in one line: SB 54 is California's extended producer responsibility law for single-use packaging and plastic food service ware, run through Circular Action Alliance, the first PRO CalRecycle approved, with PRO fees beginning January 1, 2027.
PRO Registration
Join a CalRecycle-approved Producer Responsibility Organization (PRO). Deadline passed — backfill registration now to avoid compounding penalties.
Reporting & Source Reduction
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.
PRO Fees (2027)
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.
California EPR fees under SB 54
California EPR fees are paid to the PRO, Circular Action Alliance, beginning January 1, 2027. They are calculated on the covered material you report, by material category and weight, and eco-modulation adjusts the rates for recyclability. The final fee schedule depends on the PRO's program plan, which CalRecycle had not yet approved as of October 9, 2026 — so any figure today is an estimate.
Are you a "covered producer" under SB 54?
You are likely covered if you sell or distribute products in California using any of the following:
- Plastic packaging of any kind — rigid, flexible, or film
- Paper or cardboard packaging (fiber-based covered material)
- Glass or metal packaging sold as consumer goods
- Multi-material packaging with a covered component
- E-commerce fulfillment packaging shipped to California addresses
Whether the obligation falls on your company or on another party in the supply chain depends on the producer hierarchy — see who is the producer under EPR law.
Below the $1 million threshold?
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 it is valid for two years before it has to be renewed.
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 worksKnow your California obligations — delivered in 5 business days.
The 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
Get Your EPR Blueprint