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On February 19, 2026, we attended the Circular Action Alliance ("CAA") California EPR Update Webinar. CAA is the Producer Responsibility Organization ("PRO") implementing California's packaging EPR law, Senate Bill ("SB") 54. During this webinar, CAA leadership discussed CAA's plans and goals for California in 2026.
To set the stage, SB 54 has experienced significant delays in implementation with draft regulations recalled twice now, most recently in January. CalRecycle, the state agency in charge of SB 54, quickly turned around revised regulations for an additional 15-day comment period, which ended on February 13. CalRecycle must now consider the comments and resubmit the revised regulations to the California Office of Administrative Law for approval. If final regulations are filed with the California Secretary of State by February 28, they will become effective April 1, 2026. Any later and they will not become effective until at least July.
Pressure is building as statutory deadlines remain unchanged and CAA is up against a tight implementation schedule, which has been made significantly more difficult without formal regulations to guide the process.
Below are a few key points from CAA's Webinar.
- CAA confirmed that they are still working towards a June 15,
2026 submission of the Program Plan to the Producer Responsibility
Advisory Board.
- The Advisory Board and the public will then have 60 days to comment on the proposed Program Plan.
- CAA plans to issue an initial guidance document for producers soon which will include a tentative compliance timeline.
- CAA is encouraging producers to report their 2023 source
reduction baseline data to CAA as soon as possible.
- The deadline will be 30 days after the SB 54 implementing regulations take effect. This date is still uncertain.
- Producers who submit their data early will have an opportunity to update their data during the 30-day period after the regulations are finalized.
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