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On January 23, 2026, we attended the SB 54 Packaging Producer Responsibility Advisory Board's first meeting of the year. The Board received updates from both CalRecycle and Circular Action Alliance (CAA), California's Producer Responsibility Organization (PRO).
As we previously noted, CalRecycle withdrew its final SB 54 implementing regulations on January 9, the day they were previously expected to be approved. CalRecycle confirmed that it is actively working on the regulations and an additional 15-day public comment period for the revised regulations will be announced in the coming weeks.
CAA expects to submit its Program Plan to the Advisory Board by the June 15, 2026 deadline. The Board will then have 60 days to review the plan. CAA stated that the Program Plan will be publicly available online during this 60-day period. CAA continues to ask producers to report their material data as soon as possible and not to wait until the implementing regulations are finalized.
Producers should monitor the release of the revised regulations and prepare to quickly respond during the 15-day comment period, if desired. We will continue to monitor for SB 54 updates as well as EPR program updates across the country.
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