Producers of plastic packaging in California are entering the first phase of compliance under the state's extended producer responsibility (EPR) law, with a 1 June deadline to register and begin reporting.
The deadline marks the first major test of the law, known as SB 54, since final rules were approved on 1 May. Producers must register with the Circular Action Alliance (CAA), apply to comply independently through CalRecycle, or file for an exemption. They must also begin submitting historical data on the types and volumes of packaging they produce for the California market.
Many producers say they are still working through how to meet the requirements, with uncertainty around reporting obligations. Compliance strategies are likely to vary widely by company, a recycler said.
Uncertainty also remains about how fee assessments will be calculated and how costs will flow through supply chains, particularly for packaging and resins tied to recycled content markets.
"The strategy for determining how to comply will vary by producer," a market participant said, noting that differing approaches could lead to uneven cost impacts across the sector.
Data submitted under the 1 June deadline will form the basis for fee calculations, with initial invoices possible in late 2026 and full fee collection beginning in 2027, according toCalRecycle.
Producers that fail to register or report could face penalties of up to $50,000/d per violation, with enforcement escalating over time.
SB 54 sets long-term targets, including a 25pc cut in single-use plastic packaging, a 65pc recycling rate, and 100pc recyclability or compostability of covered materials by 2032.
"There is no clear sign of inventory build ahead of the deadline, with most producers taking a wait-and-see approach as guidance continues to emerge," a producer said.
The law is expected to reshape demand in the recycled plastics market by linking producer fees to recyclability. Packaging that is easier to recycle may face lower costs, while harder-to-recycle materials could carry higher fees. The structure incentivizes the use of post-consumer resin, which may become more attractive as producers look to manage compliance costs.
By Dona Davis
