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On March 20, 2026, we attended the Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54) Advisory Board Meeting. The Board received important updates from CalRecycle and Circular Action Alliance (CAA), California's Producer Responsibility Organization.
At the meeting, CalRecycle informed the Board that they completed their review of the public comments to the latest draft of the SB 54 regulations and submitted the revised regulations to the California Office of Administrative Law (OAL) for review on March 19, 2026.
OAL has until May 1, 2026, to complete its review of the regulations. CalRecycle has requested an early effective date from OAL. If OAL agrees and approves the regulations, they will take effect the same date they are approved.
Once the regulations are approved, obligated producers will have 30 days to submit their data to CAA. This means producers should be ready to report all of their data by May 30, 2026—including 2023 data, 2025 data, and source reduction data. Producers that have not yet begun this process may wish to start as soon as possible, as the reporting requires a significant amount of data.
Finally, CAA informed the Board that it is on track to submit its Program Plan by the June 15, 2026, deadline. There will then be a 60-day public comment period, after which CAA will have 60 days to revise the Program Plan before submission to CalRecycle.
We will continue to monitor for SB 54 updates as well as EPR program updates across the country. For more information on SB 54, please see our previous articles, including Looking Forward: Circular Action Alliance's Plans for California in 2026 and SB 54 Advisory Board Meeting: Rescinded Regs and Reporting Requests.
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