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CalRecycle has withdrawn proposed regulations for implementing California’s Plastic Pollution Prevention and Packaging Producer Responsibility Act, otherwise known as SB 54.
The agency intends to change the regulations to improve clarity and help implement the law, according to an email sent late on the afternoon of Jan. 9. The revisions will largely focus on food and agricultural commodities.
Although deadlines for the law are unchanged, CalRecycle will hold an additional 15-day comment period, but the agency has not yet announced dates.
This is only the latest in numerous delays for the sweeping EPR legislation. In late April 2025, Circular Action Alliance, the producer responsibility organization (PRO) administering the program, proposed tweaks to accommodate delays and still meet the implementation deadline.
In a December 2025 update, CEO Jeff Fielkow said CAA was on track to submit its program plan in June 2026, in line with previous expectations of “mid-2026.” The SB 54 advisory board then will review the plan and provide written comment, and by Jan. 1, 2027, CalRecycle must approve the PRO plan and the program will begin.
Anja Brandon, director of plastics policy at the Ocean Conservancy, has been involved in the process to develop SB 54. She said in a statement she was not surprised at the withdrawal. “The draft proposed would have gone beyond CalRecycle’s authority by creating a sweeping categorical exclusion for food and agricultural packaging — effectively a loophole that would have allowed producers to continue putting vast amounts of plastic packaging into the marketplace, completely undermining SB 54’s goals and success. No product should be permanently exempt from complying with the law, there is already a clear path for materials that face extra challenges to comply. This reset is an important opportunity for the administration to eliminate categorical exclusions altogether and ensure the regulations align with the statute’s intent.”
California’s Legislature passed SB 54 in 2022, and Gov. Gavin Newsom signed it into law the same year.
But in March 2025, Newsom rejected the draft EPR program language due to concerns over the costs to small businesses, delaying implementation and forcing the rulemaking process to restart.
