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California Packaging EPR Compliance Guide — 2026

Everything brands need to know about Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54), including deadlines, data requirements, material categories, exemptions, and reporting preparation.

Check your California readiness
Key Facts
LawSB 54 — Plastic Pollution Prevention and Packaging Producer Responsibility Act
AdministratorCalRecycle
PROCircular Action Alliance (CAA)
EffectiveSigned June 30, 2022; regulations effective May 1, 2026
RegistrationProducers must register with CAA or CalRecycle by June 1, 2026.
ReportingAnnual supply reports are required, with first reports expected in 2027.
ExemptionGenerally less than $5M in global gross revenue and less than $1M in California gross revenue.
Who Needs to Comply

The obligated producer is generally the brand owner, licensee, importer, distributor, or retailer responsible for covered material sold or distributed in California.

All packaging and food service ware placed on the California market, with phase-in details by material and use case.

Small producer note: Generally less than $5M in global gross revenue and less than $1M in California gross revenue.

What Data You Need
  • SKU-level sales into the state
  • Packaging BOMs for covered SKUs
  • Component material categories
  • Component weights in grams
  • PCR and recycled content
  • Recyclability and evidence files

Key Deadlines

Regulations effective
May 1, 2026
Producer registration
June 1, 2026
Individual Source Reduction Plan
August 1, 2026
First annual supply report
May 31, 2027

Material Categories for California

These are common packaging categories brands should be ready to classify and report. Always follow final state and PRO instructions.

MaterialClassCalifornia note
PETPlasticCommon priority material for this state.
HDPEPlasticCommon priority material for this state.
PVCPlasticReport PVC separately when identified as vinyl, PVC, or resin code #3.
LDPEPlasticReport as LDPE or #4 plastic when supplier documents state low-density polyethylene.
PPPlasticCommon priority material for this state.
PSPlasticReport rigid PS separately from EPS foam where programs distinguish the two.
EPSPlasticCommon priority material for this state.
Other PlasticPlasticUse only when the resin is unknown or explicitly categorized as other/#7 plastic.
Multi-layer PlasticPlasticUse when the package includes multiple plastic layers or barrier materials that prevent single-resin classification.
Small-format PlasticPlasticUse where reporting programs separate small-format plastics from regular resin categories.
Clear GlassGlassCommon priority material for this state.
Brown GlassGlassUse brown/amber glass category when documents call out amber, brown, or UV-protective glass.

How to Report

  1. 1Confirm whether your company is a covered producer or qualifies for an exemption.
  2. 2Register with the PRO or CalRecycle by the applicable deadline.
  3. 3Build SKU-level packaging BOMs with component weights, materials, recyclability, and recycled content.
  4. 4Prepare annual supply data and retain supplier evidence for audit support.
Common Mistakes
  • • Using finished product weight instead of packaging component weight.
  • • Grouping all plastics together instead of classifying PET, HDPE, PP, EPS, and other categories separately.
  • • Missing source reduction planning requirements for high-volume or covered producers.

Penalties for Non-Compliance

CalRecycle has enforcement authority, including potential penalties for producers that fail to register or report.

Frequently Asked Questions

Does California SB 54 apply to out-of-state brands?

Yes. If your packaged products are sold or distributed into California and you meet the producer definition, you may have obligations even if your company is based elsewhere.

What packaging data should brands collect for California?

At minimum, collect SKU-level units sold into California, each packaging component, material category, component weight in grams, recycled content, recyclability, supplier, and supporting evidence.

Does PackBOM calculate final California EPR fees?

No. PackBOM organizes data and builds report-ready exports. Final fee calculations are set by the PRO and regulators.

Can AI extraction be used for SB 54 data collection?

AI extraction can speed up spec sheet review, but a human should confirm every extracted material and weight before the data is used for compliance reporting.

Are food service ware items covered?

California SB 54 covers packaging and food service ware, subject to definitions, exemptions, and implementation rules.

How PackBOM helps with California compliance

PackBOM connects SKU sales, packaging BOMs, supplier evidence, AI spec extraction, validation rules, and report exports so your California data is ready for review.

Start your California EPR Data Audit

Related Resources

EPR Obligation Checker

Check whether your brand may need to comply with packaging EPR.

EPR Deadline Tracker

See deadlines across all current EPR states.

Multi-State EPR Checklist

Prepare data across California, Oregon, Colorado, and other states.