SB 54 is still scheduled to go live January 1, 2027. The problem is that the official regulations brands need to actually comply with don't exist yet, and the path to getting there has been anything but straight.

If you're a brand selling into California and trying to figure out what EPR compliance actually requires of you, you're facing a genuinely frustrating situation: a landmark packaging law with a live launch date, a compliance infrastructure that's being assembled in real time, and regulations that have been proposed, rejected, withdrawn, and restarted. And there is no final version anywhere in sight, yet.

This isn't speculation or alarmism. It's the documented state of play for California's SB 54, and it's worth understanding clearly, because the right response to regulatory uncertainty isn't to ignore it. It's to understand what's fixed, what's fluid, and what you can actually do right now.

Quick Intro on CalRecycle and the CAA

As we dive into how EPR is shaping up in California, there are a few key players we want to quickly introduce:

• CalRecycle is California’s agency managing the state’s waste diversion and recycling programs, focused on building a circular economy. 

• The Circular Action Alliance (CAA) is a non-profit Producer Responsibility Organization (PRO) approved by CalRecycle to implement the state's SB 54 Extended Producer Responsibility (EPR) law. 

So essentially, CalRecycle sets regulations and enforces compliance, whereas CAA collects fees, reports data, and manages recycling systems on behalf of producers.

What SB 54 actually requires

California's Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54) was signed into law in 2022. The mandate is sweeping and require many changes by 2032:

• All single-use packaging sold in California must be recyclable or compostable

• Single-use plastic packaging must be reduced by 25 percent from 2023 levels

• With ultimately a 65 percent recycling rate for packaging

• A $500 million per year Plastic Pollution Mitigation Fund will be funded by covered producers

These are statutory requirements written into the law itself, not into the regulations. They don't go away because the rulemaking process is delayed. The January 1, 2027 program start date is embedded in the statute. It has not moved.

What the regulations are supposed to do is define the specific mechanisms:

• How fees are calculated and how eco-modulation works (the system that adjusts fees or provides credits based on environmental packaging)

• What reporting formats look like

• How the Circular Action Alliance manages SB54 and administers the program

• What constitutes compliance for specific packaging categories

Without final regulations, brands know they're obligated, but they just don't know exactly how.

Where the rulemaking stands now

The core issue with CalRecycle's first set of proposed regulations was twofold. Governor Newsom rejected them in March 2025, citing concerns about cost burdens on small businesses and the need for equitable implementation. Then, when CalRecycle put out a revised draft, environmental advocates objected on the opposite grounds: arguing that the revision had gone too far in creating exemptions for food and agricultural packaging, effectively creating a loophole that would have let a significant category of plastic packaging avoid compliance obligations altogether.

CalRecycle's January 2026 withdrawal of the proposed regulations reflects an attempt to resolve that tension. The agency is now revising again, with a specific focus on the food and agricultural packaging provisions that drew the most criticism.

The brand planning problem: a law that is real, a launch date that hasn't moved, and regulations that are still being written. This is the situation as of April 2026.

What's actually known (and what isn't)

Despite the regulatory uncertainty, several things are fixed and brands can plan around them:

The January 1, 2027 program start date is statutory, not regulatory. It doesn't require a regulation to be in force. Barring legislative action to amend the law itself, this date holds. The CAA's program plan submission in June 2026 and CalRecycle's approval of that plan are the milestones between now and then.

CAA has been approved as California's PRO. Registration with the Circular Action Alliance is the operational first step for any brand with California obligations. That process is underway and brands should be registered now or in the immediate near term.

Early fee invoices will be based on 2025 packaging data. This is unique to California. Oregon and Colorado based their initial fees on prior-year data. California's early fees will be based on 2025 data, which compresses the preparation window considerably. Brands that don't have 2025 packaging data organized and reportable are already behind.

The eco-modulation framework is directionally established. While the specific fee rates and modulation percentages aren't finalized in regulation, the Covered Material Category list (94 categories of packaging with recyclability determinations) was published by CalRecycle on December 31, 2025. The general direction of what grades favorably and what doesn't is knowable now, even if the precise fee structure isn't.

California's data reporting requirements are the most granular in the world. This is also knowable in advance of final regulations: California requires component-level data: material type, weight per component (not just total package weight), resin color, food-contact status, recyclability status under the Covered Material Category framework. For brands that have been reporting in Oregon and Colorado, California will ask for more. For brands that haven't started, the gap is significant.

What the regulatory uncertainty actually means for planning

Here's the practical implication: the absence of final regulations doesn't mean brands can't prepare. It means brands need to distinguish between what they can do now and what needs to wait until the regulations are finalized.

What you can do now: Register with the CAA. Organize your 2025 packaging data at the component level. This is what California will ask for, and building that data set takes time regardless of which specific reporting format the final regulations require. Assess your packaging portfolio against the Covered Material Category list to understand your preliminary fee exposure profile. Make any low-friction material changes (PVC to PET sleeve swaps, PCR certification for existing bottles) that improve your eco-modulation grade and that you'd make regardless of which version of the regulations gets finalized.

What requires the regulations to be finalized: Precise fee modeling, specific reporting format compliance, and any decisions that depend on knowing the exact eco-modulation rate for a specific material category. These can't be locked down until the regulations exist, but they can be scoped and ready to finalize quickly once the regulations are published.

The brands that will be in the best position when final regulations are published are the ones that used the regulatory uncertainty window to build the data infrastructure, clean up their packaging data, and make the easy material decisions. The ones that wait for final regulations before doing anything will be doing all of that under time pressure.

The bigger picture: California's scale means this matters nationally

California is the fourth-largest economy in the world and the largest single consumer goods market in the United States. Most national brands use consistent packaging across all states, which means California's requirements, once finalized, will effectively function as a national packaging standard for any brand that doesn't want to maintain California-specific SKUs.

That's the reason California's regulatory situation matters even for brands where California is just one market among many. Because when California finalizes the eco-modulation framework, the recyclability standards, the labeling requirements, they set a de facto national floor. The delay in getting there doesn't reduce that eventual impact. It just delays the point at which brands have full clarity on what it requires.

California's labeling requirements alone (once finalized under SB 343, with an anticipated effective date in late 2026) may effectively determine what "recyclable" claims any brand can make on packaging sold nationally.

What sourceM is watching

We're tracking the California SB 54 rulemaking process actively: the CalRecycle revision timeline, the CAA program plan submission in June 2026, and the Advisory Board review process. As pieces of the regulatory picture become clearer, we'll update our guidance for clients.

In the meantime, the work we're doing with brands on California EPR preparedness is focused on the things that are knowable and actionable now: data readiness, portfolio assessment against the Covered Material Category list, and the material decisions that improve eco-modulation grade regardless of which version of the regulations gets finalized.

If you want to talk through where your brand stands: your specific formats, your California packaging data, and what the preliminary fee exposure picture looks like…we're happy to do that.

Sources: Resource Recycling ("CalRecycle withdraws proposed regs for SB 54," January 12, 2026); DLA Piper ("Extended producer uncertainty: Groundbreaking California packaging law faces setbacks," March 14, 2025); CalRecycle SB 54 program documentation; Circular Action Alliance California Producer Resource Center.

Note: This post is provided for informational purposes only and does not constitute legal or regulatory advice. California SB 54 compliance obligations are subject to ongoing regulatory development. Please work with qualified regulatory counsel for compliance determinations specific to your business.