California SB 54 Explained

California’s Senate Bill 54 (SB 54), also known as the Plastic Pollution Prevention and Packaging Producer Responsibility Act, was signed into law by Governor Gavin Newsom on June 30, 2022. SB 54 requires companies that sell or distribute single-use packaging or food-service ware in California to take responsibility for the end-of-life of their product packaging.

Understanding California SB 54

SB 54 shifts the financial responsibility for collecting, processing, and recycling packaging waste from local governments to producers. Under SB 54, companies that sell consumer products in California must participate in a producer responsibility organization (PRO) which will manage compliance and fund recycling efforts.

Unlike other extended producer responsibility (EPR) laws in states like Colorado, Oregon, and Maine, SB 54 also requires companies to redesign packaging. Packaging for products sold in California must meet strict standards for recyclability or compostability. Because most brands use the same packaging across the United States, these changes will likely influence packaging nationwide.

Packaging redesign often requires long lead times, including material testing and supply chain adjustments. Preparing ahead of time can help companies avoid higher future fees for packaging that does not meet California’s requirements.

SB 54 requires producers to ensure their packaging is recyclable or compostable by 2032. The law also funds statewide recycling systems and encourages companies to reduce overall packaging use, decreasing plastic waste and supporting a more circular economy.

What SB 54 Means for Companies

Companies covered under SB 54 are required to register, report packaging data, maintain records, and demonstrate progress toward reduction goals. They must also contribute to funding California’s recycling infrastructure through annual fees. 

Companies were required to register with the Circular Action Alliance (CAA) by September 5, 2025. The first reporting deadline is on November 15, 2025, when registered companies must report their packaging data via the Circular Action Alliance (CAA) online portal. 

Over time, the law encourages companies to redesign packaging, reduce material use, support reuse and refill systems, and explore non-plastic alternatives.

Covered Material Categories (CMCs) Under SB 54

SB 54 uses Covered Material Categories (CMCs) to organize and track single-use packaging and plastic food service ware. These categories help producers report, reduce, and manage packaging waste.

What Are CMCs?

• CMCs group packaging and food service items by material type, form, and whether they contain plastic.
• Each item must be classified by its dominant material (glass, ceramic, metal, paper/fiber, plastic, wood/organic).
• Items with multiple materials are categorized by the material that makes up the largest portion by weight.
• If an item has a plastic component, it is classified as “with plastic component.” If not, it is “without plastic component.”

Why SB 54 Matters

 Unfortunately, packaging accounts for over 50% of landfill waste by volume in California. But SB 54 marks a major shift in how this waste is managed. As deadlines fast approach, businesses that are already redesigning packaging, using more sustainable materials, and planning for end-of-life management are at a competitive advantage.

Exemptions Under SB 54

Some products are exempt from SB 54 requirements. These include beverage containers already covered under the California Beverage Container Recycling and Litter Reduction Act, as well as medical products, prescription drugs, certain medical nutrition products, infant formula, refillable or reusable packaging, and hazardous materials. The full list appears in the legislative text.

Small businesses are also partially exempt. Companies with less than $1 million in annual gross sales in California are exempt from most reporting and fee requirements. However, they must still ensure that all covered packaging they sell in the state is recyclable or compostable by January 1, 2032.

Because of this, even smaller brands will need to review packaging materials and plan for long-term compliance.

SB 54 Key Dates, Milestones, & Reporting Deadlines

• January 8, 2024: CalRecycle selects Circular Action Alliance as the PRO.
• January 1, 2025: Expanded polystyrene food-service producers must show a 25% recycling rate. SB 54 EPS Notice.
• September 5, 2025: Deadline for companies to register with Circular Action Alliance (CAA)
• November 15, 2025: First reporting deadline for packaging data. 
• Mid-2026: CAA (the PRO) submits its program plan.
• Mid-2026: SB 54 Advisory Board reviews the plan and provides comments.
• By January 1, 2027: CalRecycle approves the plan, and the EPR program officially begins.
• March 1, 2027: PRO submits initial California plastic pollution mitigation fees.
• July 1, 2027: PRO submits administrative fees to CalRecycle.
• 2027–2037: PRO will collect $500 million annually from consumer packaged goods companies, and up to $150 million from plastic resin manufacturers.
• By 2032: At least 65% of single-use plastic packaging and food-service ware must be recyclable.
• By 2032: Companies must reduce single-use plastic packaging and food-service ware by 25% compared to 2023 levels.
• By 2032: 100% of single-use packaging and food-service ware must be recyclable or compostable.

Frequently Asked Questions About SB 54

Who must comply with SB 54?

Any company selling or distributing single-use packaging or plastic food-service ware in California must comply. Small businesses with less than $1 million in annual sales are exempt from most reporting and fee requirements.

What types of packaging are covered?

SB 54 covers single-use packaging and plastic food-service ware, including bottles, jars, trays, cartons, wrappers, and utensils.

What are Covered Material Categories (CMCs)?

CMCs are groups that classify packaging by material type, form, and whether it contains plastic. Producers must report packaging data using these categories. Find more info here:

• Covered Material Categories List (CalRecycle)
• CMC Reporting Guidance (CalRecycle)
• SB 54 Plastic Pollution Prevention and Packaging Producer Responsibility Act Permanent Regulations

What are the key deadlines for SB 54?

• Register with Circular Action Alliance by September 5, 2025.
• Submit initial packaging data by November 15, 2025.
• Annual reporting is required.
• By 2032, all packaging must be recyclable or compostable.

What exemptions exist under SB 54?

Exemptions include beverage containers covered by California’s recycling law, medical products, prescription drugs, certain nutrition products, infant formula, refillable or reusable packaging, and hazardous materials.

What happens if my company does not comply?

Non-compliance may result in penalties, higher fees, and loss of market access in California.

How can my company prepare for SB 54?

• Register with the Producer Responsibility Organization.
• Gather and report packaging data by CMC.
• Redesign packaging to meet recyclability or compostability standards.
• Maintain records and plan for annual fees.

Where can I find more information?

Visit CalRecycle’s SB 54 page and the Covered Material Categories List (linked above) for official guidance.

Partner with Paramount Global for Sustainable Packaging Success

At Paramount Global, we support brands as they navigate SB 54 and build packaging strategies that meet both compliance and sustainability goals. Our team helps simplify material selection, sourcing, and packaging redesign, so you don’t have to figure it out alone. We work closely with you to create packaging that protects your product, strengthens your brand, and aligns with evolving regulations. As the industry shifts, we are here to guide, support, and partner with you each step of the way.

Ready to move forward? Contact us today to discuss your packaging goals and next steps.

Want more info? Check out our other blog posts for more on sustainability: 

• What is Extended Producer Responsibility (EPR)?
• 5 Steps to Improve the Sustainability of Your Packaging
• How to Transition from Virgin to Recycled Plastics in Packaging
• Designing Plastic Packaging for Sustainability
• A Guide to Material Sourcing