ARTICLE
20 August 2025

Watch For Deadlines Under California's Packaging Extended Producer Responsibility Regulations

BD
Beveridge & Diamond

Contributor

Beveridge & Diamond’s more than 125 lawyers across the U.S. offer decades and depth of experience advising numerous industry sectors on environmental law and its changing applicability to complex businesses worldwide. Our core capabilities encompass facilities and products; U.S. and international matters; regulatory strategy, compliance, and enforcement; litigation; and transactions.
Under California's Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54), deadlines are currently set for this Fall.
United States Environment

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. During the SB 54 Advisory Board meeting on August 15, 2025, CalRecycle stated that the public comment process for the SB 54 draft regulations will open later this month.

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.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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