CAA files California program plan for SB 54

Circular Action Alliance (CAA) has delivered its California program plan to the Packaging Producer Responsibility Advisory Board, advancing the state’s packaging EPR program toward implementation.

The producer responsibility organization (PRO) CalRecycle appointed to administer the program filed the plan following the May 1 finalization of regulations under SB 54.

The state’s landmark law requires producers to reduce single-use plastic by 25% and ensure all covered packaging is recyclable or compostable by 2032. The submission opens a public comment period running through Aug. 14, 2026.

“Today’s submission reflects the sustained collaboration that has shaped this work from the start,” said Emily Coven, CAA’s California executive director, in a statement. “The plan draws on extensive input from across California’s recycling and reuse system and is designed to work in real-world conditions.”

The plan outlines proposed pathways across recycling, reuse and source reduction. It comes as litigation over the underlying regulatory framework remains pending.

In early June, Oceana, NRDC and Californians Against Waste Foundation (CAW) sued CalRecycle in San Francisco Superior Court, alleging the finalized regulations add exemptions that undermine the law’s core mandates.

Nick Lapis, CAW director of advocacy, said the final rules added more loopholes for plastic packaging producers than CalRecycle’s earlier draft.

“These regulations ignore explicit limits on recycling technologies and create permanent escape hatches the law never authorized,” Lapis said in a statement. “CalRecycle’s original draft regulations were already not strong enough to ensure the systemic change that the public expected from this law, but the agency’s final regulations added even more loopholes to protect the status quo for producers of plastic packaging.”

Heidi Sanborn, National Stewardship Action Council (NSAC)’s executive director, said litigation should not slow implementation efforts.

“Don’t take the pedal off the metal on actual implementation,” she previously told Resource Recycling.

CAA launched producer reporting ahead of regulatory certainty last year and released fee-rate estimates in May.

“We have provided the tools necessary for producers to prepare for the program,” said Shane Buckingham, CAA chief of staff, in a statement.

The Recycling Partnership, which has been engaged with partners across California on SB 54 readiness, called the submission an “important milestone.”

“Progress on a policy of this scale only happens through a series of milestones which have been years in the making,” said Kate Davenport, TRP’s chief impact officer, in a statement. “The program plan submission moves California one step closer to supporting a more effective, transparent and accountable recycling system.”

Compliance among producers has been uneven, particularly for mid-market and smaller companies that are in scope for California but had not previously faced thresholds under other state programs.

“We are in the eye of the hurricane,” Sara Lowe, senior executive administrator at Bay Cities Packaging & Design, told Resource Recycling earlier this month. “But on the other side, if this works as intended, we’re going to have a much more robust recycling infrastructure.”