Understanding Senate Bill 54 in California: What Do We Know About the Plastic Pollution Prevention and Packaging Producer Responsibility Act?

FREQUENTLY ASKED QUESTIONS

WHY DID WE WRITE THIS GUIDE?

In June 2022, California passed Senate Bill 54, also called the California Plastic Pollution Prevention and Packaging Producer Responsibility Act, making the state a national leader in addressing the plastic crisis. This bill is an extended producer responsibility (EPR) law, meaning that under this new legislation, single-use plastic producers will have to pay for infrastructure that manages plastic waste and pollution cleanup. As this law is implemented in California, it’s important for state agencies, environmental justice and conservation advocates, and municipalities to understand why SB 54 was passed and to address questions that still remain.

This FAQ provides an overview of SB 54, including issues the law aims to address and the responsibilities of producers and regulators. Our goal is to provide one document that informs policymakers, advocates, municipal staff, and community members.

EXPERTS

Veronica Herrera, Associate Professor of Urban Planning
Daniel Coffee, Project Manager of Plastic and Climate Research
Melisa Walk, Graduate Student Researcher

KEY ABBREVIATIONS

CAA: Circular Action Alliance
CalRecycle: California Department of Resources Recycling and Recovery
CMC: Covered material categories
EPR: Extended producer responsibility
EPS: Expanded polystyrene
PPMF: Plastic Pollution Mitigation Fund
PRO: Producer responsibility organization
SB 54: California Plastic Pollution Prevention and Packaging Producer Responsibility Act

SECTION 1
Why Was SB 54 Needed?
What is SB 54?
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Takeaway: SB 54 is an extended producer responsibility (EPR) law for packaging and single-use plastic food service ware products passed on June 30, 2022. It shifts the financial responsibilities of waste management from municipalities and taxpayers to producers of packaging and single-use plastic food service ware products.

Under the law, producers are mandated to join a producer responsibility organization (PRO) that is responsible for funding the management of single-use packaging at its end of life. Producers are required to guarantee packaging is recycled or compostable, fund processing infrastructure, meet increasing recycling targets, and report on progress.

The California Department of Resources Recycling and Recovery (CalRecycle) oversees implementation of SB 54. The agency has appointed an advisory board to review the approved PRO’s plans and budgets and publish official lists of recyclable and compostable material categories. The legislation sets several targets that are intended to reduce plastic waste and transition California toward a more sustainable economy.

What problem is SB 54 trying to solve in California’s waste and plastic system?
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Takeaway: SB 54 seeks to improve recycling outcomes and reduce harms from plastic pollution, while simultaneously shifting the costs of managing single-use packaging waste from local governments to manufacturers.

SB 54 aims to reduce plastic waste generation and improve recycling and composting rates for single-use packaging, which will decrease the amount of plastic packaging sent to landfills. Packaging is a major waste management issue, making up 50% (by volume) of California’s landfill stream. Packaging also often escapes the waste system, where it becomes plastic pollution. Plastic pollution has multiple negative impacts, from increased greenhouse gas emissions through landfilling, to polluting waterways and natural ecosystems, to harming low-income communities and communities of color, which are disproportionately affected by plastic production and pollution.

Even when properly managed, packaging and single-use plastic food service ware products are notoriously difficult to recycle, with some materials having recycling rates of less than 5%. The cost of recycling the plastic is more than the price a recycler can sell it for. This means that recycling has historically been ineffective at addressing the plastic waste problem.

However, because SB 54 prioritizes plastic reduction, reuse, and refill systems, it may create a shift toward a more sustainable economy. The goal of SB 54 is to reduce plastic packaging overall, increase and improve recycling and composting systems, and ensure that producers are financially responsible for funding these system changes.

How does SB 54 define “plastic”?
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Takeaway: Plastic is defined as a synthetic or partially synthetic material derived from fossil fuel production and organic substances; producers must achieve source reduction of the material to be in compliance with the law.

SB 54 defines plastic as a synthetic or partially synthetic material and includes specific plastic types commonly used in packaging and consumer products. Examples of covered plastic types include polyvinyl chloride (PVC), used in piping; high-density polyethylene (HDPE), used in shampoo, detergent, and milk bottles; and polyethylene (PE), used in plastic wrap and bags. Traditional plastic manufacturing isa part of the larger fossil fuel industry because it is made from refined crude oil and natural gas. This makes plastic a major contributor to global climate change. Plastic manufacturing is also increasingly integrated with the broader petrochemical industry. The environmental and human health impacts of plastic disproportionately affect low-income communities and communities of color, which often bear the burden of the entire plastic lifecycle (see Question 4 below).

Though bioplastic is made from plant-based materials rather than fossil fuels, bioplastic is still categorized as plastic under the law’s language and must comply with source reduction targets.

What is the lifecycle of plastic, and how does it impact public health and the environment?
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Takeaway: Plastic creates environmental, public health, climate, and environmental justice impacts throughout every stage of its lifecycle—the entire process through which it is created, used, and disposed of.

The plastic lifecycle refers to all of the stages a plastic product goes through, from the extraction of raw materials and product manufacturing to product use, disposal, and eventual management as waste. At each stage, plastic production and waste management can have significant environmental, public health, and environmental justice impacts on communities and ecosystems situated near extraction, manufacturing, and waste management infrastructure or impacted by plastic litter. Plastic production is also a major source of greenhouse gas emissions, contributing to global climate change and ecological degradation.

The plastic lifecycle is often divided into three stages: upstream, midstream, and downstream. The upstream stage includes the extraction of fossil fuels such as crude oil and natural gas through drilling and fracking, as well as the transportation and storage of materials prior to manufacturing. The midstream stage includes the design, manufacture, packaging, distribution, and use of plastic products. The downstream stage includes the disposal, collection, sorting, recycling, export, incineration, and landfilling of plastic waste. This is often the most visible stage of plastic pollution. Much of the plastic that is not recycled or safely disposed of ultimately enters natural ecosystems, including rivers, oceans, and soil systems, where it can harm marine and terrestrial life and contaminate our food system.

ADDITIONAL RESOURCES
  • UCLA Luskin Center for Innovation report: What Defines a Plastic-Burdened Community? — Part I (Herrera and Coffee, 2024)
  • SB 54 bill text (June 30, 2022)
  • UCLA Luskin Center for Innovation report: The Perils of Plastic (Coffee and Diaz, 2022)
  • World Economic Forum, Ellen MacArthur Foundation and McKinsey & Company, The New Plastics Economy: Rethinking the future of plastics (2016).
  • UCLA Luskin Center for Innovation report: What Defines a Plastic-Burdened Community? — Part II (Herrera and Coffee, 2025)
  • CalRecycle Website: Plastic Pollution Prevention and Packaging Producer Responsibility Act (June 2026)
  • Natural Resources Defense Council Issue Brief: Behind the "Chemical Recycling" Curtain (June 2026)
SECTION 2
How the EPR System Works
What is a producer responsibility organization (PRO), and what does it do?
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Takeaway: Under SB 54, a PRO shifts financial responsibility for packaging waste management from local governments to producers.

A producer responsibility organization—commonly referred to as a PRO—is an entity made up of producers to help manage the end-of-life disposal of certain products. Within an EPR framework, the PRO ensures there is adequate infrastructure and funding needed to address waste management for local municipalities.

Producers can join the state-approved PRO, which files plans, reports, and pays fees on their behalf. CalRecycle approved the Circular Action Alliance (CAA), a producer-led nonprofit organization that provides services to producers across the United States, to comply with new EPR legislation. CAA is the single PRO to manage the statewide program to ensure a standardized set of rules and fees for companies in California. Under SB 54, the PRO is also mandated to pay California $500 million per year for 10 years for a Plastic Pollution Mitigation Fund to support communities affected by plastic pollution.

Producers can join the PRO to comply with the law, or they can meet targets independently. If producers comply independently, they must register, report, and demonstrate compliance individually. Small producers—whose gross annual sales are less than $1 million—are exempt from many compliance obligations. However, small producers are still required to register with CalRecycle and file detailed information on sales, distribution, and covered material used.

Who is considered a “producer” under SB 54?
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Takeaway: A producer is a company that sells single-use packaging and plastic food service ware with gross sales of more than $1 million.

In most cases, “producers” under SB 54 refer to the manufacturer of the product or the company whose name appears on the packaging. However, the law creates a framework to determine responsibility when multiple parties are involved in producing or selling a product.

If the manufacturer is not located in California, responsibility may shift to the owner or exclusive licensee of the brand or trademark associated with the product. If neither of those entities is based in the state, then the company or person selling or distributing the product in California may be considered the producer for compliance purposes.

The law also includes some exemptions. For example, farmers who grow and package agricultural commodities on site are not considered producers under SB 54. Additionally, a product is considered sold “in the state” if it is delivered to a purchaser in California, even if the company itself is located elsewhere.

What products and materials does SB 54 regulate?
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Takeaway: SB 54 divides different materials into “covered material categories.” Most types of covered material are regulated under SB 54, but there are varying levels of compliance pressure for each material.

SB 54 organizes materials into 95 covered material categories (CMC), which include single-use glass, metal, paper, cardboard, and plastic products. CalRecycle is required to update the CMC list annually to reflect new recycling and composting data.

Not all covered materials face equal compliance pressure. Most metal and many paper-based materials already meet recycling standards (i.e., cardboard carries an estimated 68% recycling rate). Plastic presents a much bigger challenge: flexible films, foam containers, plastic-coated paper, and most mixed plastic have recycling rates below 5%. This means producers that primarily manufacture and sell those materials face the greatest burden to redesign, switch materials, or invest in recycling infrastructure. By 2032, producers must ensure that 65% of every covered material is either recycled or compostable.

What is the role of CalRecycle in implementing SB 54?
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Takeaway: CalRecycle serves as the primary regulatory and oversight agency responsible for implementing and enforcing SB 54.

CalRecycle is responsible for overseeing the PRO, ensuring it reports, collects fees, and registers producers. The agency is also responsible for the statewide Needs Assessment, which was conducted in February of 2026, to evaluate the state’s recycling and composting infrastructure. The Needs Assessment was a critical first step to understanding the condition of waste management infrastructure in California, allowing the PRO to determine how much investment is needed from industry partners. CalRecycle also has the ability to issue civil penalties of up to $50,000 per day per violation for noncompliance with SB 54’s requirements. Finally, CalRecycle is obligated to continuously update the CMC list because it determines which materials must meet mandatory recycling and composting targets.

How will SB 54 be funded, and who pays for implementation?
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Takeaway: Producers fund the implementation of SB 54 by paying fees that support recycling, composting, and waste management systems throughout California.

SB 54 is funded through an extended producer responsibility (EPR) system, which shifts the financial responsibility for packaging waste management from local governments and taxpayers onto producers and packaging companies. Under the law, companies that manufacture, sell, distribute, or import covered single-use packaging into California are required to fund the collection, recycling, composting, processing, and disposal systems associated with their products at the end of their lifecycles.

Producer fees under SB 54 are “eco-modulated,” which means companies pay different rates depending on the specific characteristics of their packaging. Fees may be adjusted based on factors such as recyclability, compostability, toxicity, and the use of hazardous chemicals. The law is designed to incentivize producers to redesign packaging using materials that are easier to recycle, reuse, or compost. The law also reduces some financial burdens previously placed on local governments by making producers responsible for establishing and funding reliable end markets and waste management systems for covered materials.

ADDITIONAL RESOURCES
SECTION 3
What SB 54 Is Trying to Achieve
What are the main reduction and recycling targets required by SB 54?
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Takeaway: SB 54 implements a phased approach to reduction targets that become increasingly stringent over time.

By 2032, producers must meet the statewide targets established by SB 54 for single-use packaging and plastic food service ware sold in California. Covered producers (those with gross annual sales of more than $1 million) are required to source reduce plastic packaging by 25% through measures such as eliminating unnecessary packaging, shifting to reuse systems, or redesigning products. In addition, 65% of single-use plastic packaging and food service ware must be recycled, and 100% of covered materials must be recycled or compostable by 2032.

These targets are intended to reduce the amount of plastic waste sent to landfills, decrease environmental pollution, and shift California’s packaging system away from single-use materials that are difficult or economically unfeasible to recycle.

How does SB 54 define and support reuse and refill systems?
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Takeaway: SB 54 uses reuse and refill systems as a way to combat waste before it is created, making reuse one of the law’s only mandated sub-targets.

Rather than managing waste after it’s made, reuse and refill systems aim to prevent it from being created in the first place by keeping packaging in circulation for multiple uses. SB 54 defines reuse and refill systems along two tracks: (1) producer-managed systems, where companies design, recover, inspect, and reintroduce packaging back into the supply chain, and (2) consumer-managed systems, where individuals refill packaging themselves through bulk or wholesale retail stores. In both cases, the law requires that packaging be explicitly designed for multiple uses, durable enough to withstand repeated use, and supported by the required infrastructure.

The law requires a 25% reduction in single-use plastic packaging by January 1, 2032, with no less than 10% of that reduction achieved specifically through reuse or refill systems. This makes reuse one of the few areas where SB 54 sets a dedicated sub-target rather than leaving the pathway to producer discretion.

What role does composting play under SB 54?
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Takeaway: Composting is an alternative to recycling under SB 54, but its success depends on the availability of composting infrastructure.

Composting can be used as an alternative to recycling under SB 54 for materials that cannot meet the recycling standards. The law requires that by 2032, all covered packaging and food service ware be either recycled or compostable. It’s important to note that composting functions largely as a backup option to recycling rather than having its own targets.

However, the success of compostable packaging depends on the existence of collection and processing infrastructure capable of handling compostable materials. Historically, many composting facilities have not accepted compostable packaging because it can be difficult to tell them apart from conventional plastic, increased contamination risks, and they may not break down quickly enough for a facility’s production schedule. California’s SB 1383, which requires the diversion of organic waste from landfills to reduce methane emissions, could support SB 54, resulting in greater investment in composting infrastructure and organizing waste collection systems.

What role does recycling play under SB 54?
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Takeaway: CSB 54 uses recycling as its main process to reduce waste from landfills.

Recycling is the main tool through which SB 54 aims to reduce plastic pollution and divert waste from landfills. The law establishes recycling targets that increase in the next few years—30% by 2028, 40% by 2030, and 65% by 2032—for covered single-use plastic packaging and food service ware. Through the CMC system, CalRecycle evaluates whether packaging materials can realistically be recycled within California’s waste management infrastructure. Producers may face increasing pressure to redesign or replace altogether materials that do not meet the recycling standards.

California’s recycling system still faces many challenges. Plastic materials are often dirty or mixed with other materials, making them difficult to recycle. At the same time, the market for recycled plastic is not predictable, and making products from recycled plastic is often less profitable than making them from new plastic. Plastic destined for recycling is often exported as plastic waste scrap overseas, which may create additional environmental burdens for importing countries when plastic waste is not turned into recycled plastic. Many packaging formats, including plastic films, multilayer materials, and some flexible packaging, remain difficult to recycle because recycling them is often too expensive. As a result, one of the key questions surrounding SB 54 is whether recycling targets will drive meaningful packaging redesign or simply encourage the expansion of recycling technologies that remain controversial among environmental and environmental justice advocates.

What materials or packaging types are likely to be phased out?
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Takeaway: Depending on compliance thresholds, some materials may be phased out if they cannot meet recycling targets.

Under SB 54, food service ware producers were required to demonstrate a statewide recycling rate of 25% for expanded polystyrene (EPS) by January 1, 2025. Because the goal was not met, EPS food service ware can no longer be sold or distributed in California.

Other packaging types that may face increasing pressure to be phased out include plastic films, multilayer packaging, laminated materials, and packaging formats that combine multiple materials. CalRecycle’s January 2026 CMC list indicates that many of these categories have very low recycling rates (below 5%) or insufficient information to determine a recycling rate. As producers work to meet SB 54’s source reduction and recycling targets, some of these packaging formats may be redesigned, replaced with recyclable alternatives, or shifted toward reuse and refill systems.

ADDITIONAL RESOURCES
  • UCLA Luskin Center for Innovation report: Plastic Waste in Los Angeles County: Impacts, Recyclability, and the Potential for Alternatives in the Food Service Sector (J.R. DeShazo, et al., 2020)
  • Natural Resources Defense Council Fact Sheet: The Worst of the Worst: High-Priority Plastic Materials, Chemical Additives, and Products to Phase Out (October 2023)
  • Environmental Research Letters Article: Plastic Pollution Hotspots: Global Waste Trade and Environmental Risk in Latin America (Veronica Herrera, et al., 2026)
  • CalRecycle: Expanded Polystyrene Food Service Ware Requirements (January 2025)
SECTION 4
What Questions and Challenges Remain?
What is the significance of the approved regulation?
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Takeaway: SB 54 aims to reduce plastic waste and pollution, but disagreement remains over whether the final regulations will create loopholes for industry and whether recycling practices will be safe for communities and the environment.

The final SB 54 regulations have sparked debate among environmental organizations, industry groups, and policymakers regarding how the law should be put into practice. Some environmental groups have criticized parts of the regulations, arguing that they weaken SB 54’s original goals to reduce plastic packaging and improve recycling.

The exemption process for food and agricultural packaging has been a major source of debate. Critics are concerned that the exemptions could create loopholes, allowing some producers to avoid compliance requirements under the law.

Another major area of debate is how the regulations decide which recycling technologies are used under the law. The final regulations state that traditional mechanical recycling facilities operating in California before January 1, 2023, do not produce much hazardous waste. The regulations also say that hazardous waste managed under state permits is not automatically considered a large environmental or public health risk.

Critics argue that this understanding lessens SB 54’s original statutory language, which seemed to exclude recycling technologies that created large amounts of hazardous waste. Natural Resources Defense Council (NRDC) and Californians Against Waste have raised concerns that the regulations could allow polluting recycling processes, such as chemical recycling, to qualify under SB 54 so long as hazardous waste generated by those processes is managed through existing permitting systems.

What is “chemical recycling,” and what role does it play within the political context of the bill?
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Takeaway: Chemical recycling is a process to break down plastic to its liquid form, which can then be used to create a new product; however, some researchers and advocates consider this type of recycling hazardous to human health.

“Chemical recycling,” also called “advanced recycling,” is a group of technologies that use heat, solvent, pressure, or chemical processes to break down plastic into its basic building blocks. These materials may then be used to make fuels, raw material for manufacturing, or new plastic products. Two common types of chemical recycling are hydrolysis and pyrolysis.

Environmental advocates, environmental justice organizations, and some researchers have concerns about the environmental and public health impacts associated with the chemical recycling industry. According to Duke University’s Plastic Pollution Working Group, chemical recycling facilities require significant energy and financial investment that may pose a threat to communities already burdened by pollution. NRDC’s analysis of chemical recycling facilities shows they produce large amounts of hazardous waste while leading to very little plastic recycling.

Since the final SB 54 regulations state that hazardous waste managed under applicable permits does not necessarily constitute a substantial environmental or public health risk, critics argue this interpretation could allow some chemical recycling technologies to qualify under SB 54 despite concerns about pollution and hazardous byproducts.

What is the implementation timeline for SB 54?
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Takeaway: The implementation timeline for SB 54 includes escalating reduction and recycling targets, with the goal of making all packaging and single-use plastic food service ware products recycled or compostable by 2032.

SB 54 is being implemented in phases to gradually bring producers into compliance. Companies can either participate through the state-approved PRO or comply independently. The law establishes a series of targets that become stricter between 2027 and 2032 to reduce and recycle single-use plastic packaging and food service products sold in California.

The first compliance target is January 1, 2027, when producers must meet a 10% reduction in single-use plastic packaging. By January 1, 2028, producers must ensure that 30% of covered single-use plastic packaging is recycled. The next phase begins in 2030, when producers are required to achieve a 20% reduction in single-use plastic packaging alongside a 40% recycling rate.

The final targets take effect by 2032. By that time, producers must achieve:

  • a 25% reduction in single-use plastic packaging,
  • a 65% recycling rate for covered single-use plastic packaging and food service ware,
  • and ensure that 100% of covered packaging materials are recycled or compostable.

The phased structure of SB 54 is intended to give industry time to reevaluate their manufacturing and product design practices and build infrastructure.

How does SB 54 address environmental justice and frontline communities?
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Takeaway: Through SB 54, producers are responsible for funding the Plastic Pollution Mitigation Fund to address the historic harm associated with plastic pollution.

SB 54 established the California Plastic Pollution Mitigation Fund (PPMF), which requires plastic producers to contribute $500 million annually from 2027 through 2037. These funds are meant to support environmental mitigation projects, ecosystem restoration, and efforts to address the public health and environmental impacts of plastic pollution across California. Fees will be collected by the CAA and then given to the State of California. CalRecycle manages the PPMF, and the legislature approves the funds and can distribute the money to multiple state agencies to fulfill the priorities of the PPMF.

SB 54 is the first EPR law in the country that mandates a producer-paid fund, marking a system-changing shift in addressing environmental issues. Most of the fund (60%) must be used to address the historic environmental and public health impacts of plastic pollution in frontline communities, with at least 75% going to residents of disadvantaged or low-income communities. The remaining funds support restoration efforts to protect natural ecosystems, with 50% benefiting residents of disadvantaged or low-income communities. Funds for natural ecosystems in rural areas also count toward this target.

What questions about SB 54 are still unresolved or under development?
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Takeaway: SB 54 has set out to accomplish ambitious targets, but its success will depend on how effectively implementation and infrastructure goals are met.

While SB 54 sets ambitious targets for reducing plastic packaging and increasing recycling, many parts of how it will be carried out are still in development. California must still build the infrastructure, collection systems, and end markets necessary to achieve the law’s long-term goals.

Several key questions remain. It is unclear whether current recycling technologies and facilities will be sufficient to meet SB 54’s recycling targets, particularly for difficult-to-recycle materials. Pending legislation—SB 1180—seeks to inform how the PPMFwill be spent by requiring projects to prioritize communities most affected by plastic pollution. Additionally, California is set to elect a new governor in November 2026, creating uncertainty around future policy priorities. Changes in leadership at regulatory agencies such as CalRecycle, which will carry out and enforce the law, could also affect these priorities.

Another major milestone is the submission of producer compliance plans by CAA, the state’s approved PRO. These plans are expected to provide important details on how producers intend to meet SB 54’s reduction, recycling, reuse, and funding requirements.

In June 2026, industry groups and Republican attorneys general from 17 states sued the State of California, arguing that the law was unconstitutional. Simultaneously, advocacy groups sued CalRecycle, stating that the regulations it published in May 2026 did not actually implement the law and created loopholes for the plastic industry.

ADDITIONAL RESOURCES

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AKNOWLEDGMENTS

We thank Julia Stein, Deputy Director at The Emmett Institute on Climate Change & the Environment, for review and insightful suggestions, and Elizabeth Pontillo for copyediting.

TABLE OF CONTENTS

Section 1: What is SB 54?

Section 2: How the EPR System Works

Section 3: What SB 54 Is Trying to Achieve

Section 4: What Questions and Challenges Remain?

Acknowledgments

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Acknowledgments

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