California packaging EPR under SB 54.

Current California SB 54 status

CalRecycle states that the Office of Administrative Law approved SB 54 permanent regulations on May 1, 2026 and that the regulations became effective upon filing. CalRecycle continues to publish producer guidance, covered-material information and implementation updates.

What SB 54 covers

CalRecycle describes covered material as single-use packaging and single-use plastic food service ware. Its covered-material categories span material classes including glass, ceramic, metal, paper and fiber, plastic, wood and other organics. The covered-material list is updated over time as CalRecycle makes recyclability, compostability and other program determinations.

The program is still changing after rule approval

Rule approval did not freeze the program. CalRecycle reported that Circular Action Alliance submitted a Producer Responsibility Organization plan on June 15, 2026, and the agency continues to publish guidance, needs-assessment materials and updates to covered-material categories.

That is why a California compliance record should retain the source and date behind each status rather than storing only a generic “compliant” label.

Entity responsibility still needs a defensible record

SB 54 is broad, but the producer analysis remains fact-specific. Companies should identify the exact legal entity associated with the relevant products, brands, packaging and commercial relationships, then preserve the evidence supporting the internal assessment.

For corporate groups, the parent company, brand name and operating subsidiary should remain separate records until the legal and regulatory facts support a specific conclusion.

What to keep in a California entity record

Official California sources

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