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If California's SB 54 rulemaking process feels familiar, that's because it is. CalRecycle has withdrawn proposed implementing regulations—signaling continued recalibration of one of the most complex packaging Extended Producer Responsibility (EPR) programs in the country.
On January 9, 2026, California's Department of Resources Recycling and Recovery (CalRecycle), the agency overseeing California's EPR program, withdrew its proposed regulations implementing the Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54) from review by the Office of Administrative Law. This is not the first time; prior SB 54 draft regulations have also been pulled back to address stakeholder concerns and technical issues before moving forward. We blogged about it here.
This time, CalRecycle has indicated that the revisions will be targeted, with a particular focus on packaging for food and agricultural commodities. Once revised, the regulations will be reissued for an additional 15-day public comment period.
CalRecycle notes that other statutory deadlines remain unchanged with the official deadline to join a Producer Responsibility Program stated as January 1, 2027.
What to do now: Producers should monitor the release of the revised SB 54 regulations closely and assess CalRecycle's changes. Given the abbreviated 15-day comment period, companies should begin evaluating potential compliance impacts now and be prepared to submit comments quickly once the revised draft is released. Producers should also continue to monitor the EPR programs being developed across the country.
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