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California's Plastic Pollution Prevention and Packaging Producer Responsibility Act, also known as Senate Bill (SB) 54, continues to move forward toward full implementation with the issuance of new guidance documents.
SB 54 is a so-called "Extended Producer Responsibility" (EPR) law with the goal of reducing single-use plastic packaging and foodware by shifting the cost of processing these materials to their producers, rather than consumers. This is done primarily by establishing a Producer Responsibility Organization (PRO), an entity that producers join and pay fees to. The PRO then implements and funds waste management, recycling, and waste reduction practices. In addition to shifting costs, SB 54 also requires that certain recycling and source reduction thresholds be met on a timeline leading up to 2032.
On September 2, 2025, the California Department of Resources Recycling and Recovery (CalRecycle), the state agency in charge of implementing SB 54, released three new documents: (1) an update to the "Covered Material Categories," (2) Covered Material Category Producer Reporting Guidance, and (3) Source Reduction Producer Reporting Guidance. These documents will help businesses develop a SB 54 compliance strategy:
1. Update to the "Covered Material Categories"
The Covered Materials Categories (CMC) are a list of various materials covered by SB 54. In general, they are broken down by material type (e.g., plastic, metal, glass, paper, etc.) and then further by the form that material takes (e.g., for plastic—bottles and jugs, flexible and film items, rigid items, etc.). Materials must be reported to the PRO based on these CMCs. CalRecycle added one new CMC, 25 PF17P (Paper and Fiber / Multi-Material Laminate / Paperboard with a Plastic Coating/Lining), to the September 2, 2025 version of the list.
2. Covered Material Category Producer Reporting Guidance
CalRecycle prepared this guidance document to help obligated producers categorize materials into the proper CMC for reporting to the PRO.
3. Source Reduction Producer Reporting Guidance
CalRecycle prepared this guidance document to help obligated producers estimate the amount of covered material they are required to report and develop source reduction plans for.
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Notably, these guidance documents do not carry legal authority and are merely informational and designed to facilitate compliance. Further, this is a rapidly evolving area of law and changes are regularly being made to the requirements. Experienced legal counsel may be necessary to ensure full compliance with the complexities of SB 54. Our team has significant experience advising companies on plastic and packaging EPR laws across the country, including SB 54.
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.
