SB 54, the Plastic Pollution Prevention and Packaging Producer Responsibility Act, was signed into law on June 30, 2022. Its goal is to create a framework that shifts waste management costs from the local government onto producers. To that end, SB 54 requires producers to (1) reduce the use of Covered Materials; and (2) ensure that all Covered Materials are recyclable or compostable by 2032.
The definition of a producer is not 100% straightforward. You are considered a producer if you are the person who manufactures a product that uses covered material and who owns or is the licensee of the brand or trademark under which the product is used in a commercial enterprise, sold, offered for sale, or distributed in the state. [1] However, if no such person is located in California, the producer of the covered material is the owner or, if the owner is not in the state, the exclusive licensee of a brand or trademark under which the product using the covered material is used in a commercial enterprise, sold, offered for sale, or distributed in the state. [2] But if there is no such person in California either, the producer is the person who sells, offers for sale, or distributes the product that uses the covered material in or into the state. [3]
To the extent you are a producer, the final regulations implementing SB 54 which went into effect May 1, 2026 have set near-term milestones with which you must comply. First, by June 1, 2026, all producers (subject to very limited exceptions) must either (1) participate in an approved Producer Responsibility Organization ( PRO ), or (2) decide to comply individually and register with CalRecycle. Depending on which path a producer decides to follow, it will also be subject to subsequent deadlines. Producers who plan to participate in an approved PRO must have a producer responsibility plan in place by June 15, 2026. If you choose to comply individually and register with CalRecycle, they must approve you, and once...
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