California SB 54 Compliance Checklist
Use this checklist to prepare packaging data, registration evidence, and reporting support for California SB 54.
1. Confirm whether your company qualifies for California's small producer exemption.
Why it matters: California has revenue-based exemption criteria.
Common pitfall: Use current global and California revenue figures, not last year's estimates.
2. Register with CAA or CalRecycle by the applicable deadline.
Why it matters: Registration is a gate before annual supply reporting.
Common pitfall: Do not wait for every supplier response before registration.
3. Identify whether an Individual Source Reduction Plan is required.
Why it matters: California has source reduction obligations beyond basic supply reporting.
Common pitfall: Treating SB 54 as only a material weight report can miss major work.
4. Create a list of every SKU sold into EPR states.
Why it matters: EPR reporting starts with state-specific sales volume by SKU.
Common pitfall: Do not use national sales as a proxy for state sales unless the program explicitly allows it.
5. Build a packaging BOM for each covered SKU.
Why it matters: Reports need component-level material and weight data, not product-level guesses.
Common pitfall: Gift sets, bundles, labels, inserts, and ecommerce mailers are often missed.
6. Classify every component into a material category.
Why it matters: Fees and reporting formats are organized around material categories.
Common pitfall: Avoid broad labels like plastic, paper, or metal when PET, HDPE, PP, paperboard, or aluminum is known.
7. Collect supplier evidence for weights and materials.
Why it matters: Spec sheets, COAs, and technical drawings support audit defense.
Common pitfall: A sales quote is not enough if it lacks material and weight details.
8. Track PCR content separately from total recycled content.
Why it matters: Eco-modulation and recycled content reporting may distinguish post-consumer content.
Common pitfall: Do not assume total recycled content is PCR.
9. Run a validation check before generating reports.
Why it matters: Validation surfaces missing BOMs, stale sales data, and incomplete supplier responses.
Common pitfall: Generating reports before resolving critical gaps creates rework.
Get help with this checklist
Start with a PackBOM EPR Data Audit and get a clear map of your packaging compliance gaps.
Related Resources
Check which states your brand should evaluate.
Learn how to build BOMs for EPR reporting.
Read the connected EPR guide and supporting resources.