SB 54: California's Packaging EPR Law — What Producers and Brands Need to Know

SB 54 is one of the most misunderstood waste laws in California. It is commonly described as a "plastics landfill ban" — but that is not accurate. SB 54 is the Plastic Pollution Prevention and Packaging Producer Responsibility Act, an Extended Producer Responsibility (EPR) law that places the financial and operational responsibility for packaging recyclability on the producers and brand owners that put packaging into the California market.

What SB 54 Actually Requires

By 2032, all single-use plastic packaging and plastic single-use food service ware sold or distributed in California must:

- Be 100% recyclable or compostable - Achieve a 65% plastic recycling rate - Meet a 25% source reduction target (less material per unit)

The law does not directly ban landfilling of plastics by end users. Instead, it forces packaging producers to redesign products to meet recyclability standards and to fund the infrastructure that processes the material.

EPS Foam Bans (Already In Effect)

Two separate EPS (expanded polystyrene foam) restrictions are already active:

Single-use foam food service ware ban — Effective January 1, 2022 for restaurants and food service businesses. Foam cups, plates, clamshells, and similar items can no longer be provided in food service.

Broader EPS packaging ban — Effective January 1, 2025. This is now in effect and significantly expands the foam restriction beyond food service.

Permanent Implementing Regulations

The permanent regulations implementing SB 54 became effective May 1, 2026. These regulations establish the operational framework for producer compliance, fee schedules, recyclability standards, and reporting requirements.

Producer Registration

Producers must register with the Circular Action Alliance (CAA), the designated Producer Responsibility Organization (PRO) for SB 54. Producer registration with CAA is required by June 1, 2026.

After registration, producers pay annual fees that support the recycling infrastructure required to meet SB 54's recovery targets. Fees are eco-modulated — producers pay more for less recyclable packaging and less for sustainable materials.

Who SB 54 Applies To

Covered producers include:

- Brand owners selling single-use plastic packaging or plastic food service ware in California - Manufacturers of covered packaging - Importers of covered packaging or finished goods packaged in covered materials

Small producer exemptions apply, but most national brands and mid-size producers are covered.

Civil Penalties

Civil penalties for EPS violations: up to $50,000 per day per violation.

How ICTV Helps

For producers and brand owners, ICTV provides material stream documentation that supports producer compliance claims, including recycled content verification and diversion reporting suitable for inclusion in producer responsibility filings.

For commercial operators downstream of producers, ICTV helps process and document plastic packaging material streams in ways that support both regulatory compliance and producer claims of recyclability achievement.