California packaging EPR: who must report, deadlines and fees
Last verified 2026-10-14
Program status: Regulations finalized — fees pending.
Who must report
The producer is generally the brand owner of packaged products sold, offered or distributed into California. If there is no brand owner in the state, the licensee or importer may be the producer. Selling direct to consumers, including online, counts.
Small-producer exemption
- Revenue: exempt below $1,000,000 (Small-producer revenue threshold).
Producer responsibility organization
Circular Action Alliance.
Upcoming deadlines
Supply report due 2026-05-31.
Fee basics
Not yet published — 2027 fee schedule in progress
Notes
SB 54 regulations finalized May 2026. Producers under $1M gross annual sales may apply for exemption. Supply report (CY2025) due May 31, 2026; baseline report and source reduction plan due Aug 1, 2026.
Sources
California state agencyEstimate based on published rules and your inputs. Not legal advice. Confirm borderline cases with your PRO or a qualified advisor.
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