Under California’s Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54), deadlines are currently set for this Fall. The draft regulations under SB 54 have a registration deadline of “30 days after the effective date of the regulations but prior to January 1, 2027,” but SB 54 does not establish a specific deadline for reporting. However, these regulations are currently under review by the state. On August 22, 2025, CalRecycle opened the public comment period for the draft regulations. CalRecycle will also hold a hybrid public hearing regarding the draft regulations on October 7, 2025, and the public comment period will end on October 7, 2025.

Nevertheless, the Circular Action Alliance has set a registration deadline of September 5, 2025. The Producer Reporting Portal will open on September 15, 2025, with a tentative reporting deadline set for November 15, 2025. While these deadlines may shift depending on the effective date of the regulations, expect that CalRecycle may not allow more than the 30 days required by the regulations. Planning in advance will allow producers additional time to evaluate the scope of the law and obtain the information needed to properly calculate packaging volume.

For more information on SB 54, read B&D’s previously published news alert.

B&D's Plastics practice counsels clients on packaging, labeling, material restrictions, recycling, recyclability, and circular economy issues relating to plastics in California, the U.S., and worldwide, and helps companies achieve product regulatory compliance without imposing undue burdens on clients and consumers. With an office in San Francisco, B&D’s experience includes successful coordination with CalRecycle on the drafting and implementation of EPR program regulations, on behalf of potentially impacted clients. Our lawyers frequently prepare and submit comments on rulemakings regarding EPR and related topics.