Tox of the Town
EPR Update: California Regulations Approach the Finish Line; Some States Just Getting Started
by Sedina L. Banks, Sherry E. Jackman, Bryce Lourié, and Kaylinn Charnley
On December 3, 2025, we attended Circular Action Alliance’s (CAA) Quarterly Update webinar. CAA is the Producer Responsibility Organization (PRO) that has been selected by states with active plastic and packaging Extended Producer Responsibility (EPR) laws to lead their programs.
Key Takeaways:
- California’s EPR Law: Senate Bill (SB) 54
- The California Department of Resources Recycling and Recovery’s (CalRecycle) implementation regulations for SB 54 are currently under review by the California Office of Administrative Law (OAL). OAL is expected to complete its review of the regulations on or around January 9, 2026.
- CalRecycle has previously communicated that it expects to finalize SB 54 implementation regulations in early 2026, but that the regulations may be delayed if OAL or CalRecycle determine that another public comment period should be held.
- CalRecycle is on track to start implementation of SB 54 in January 2027.
- CAA expects to begin accepting reimbursement applications from local jurisdictions in early 2026.
- CAA expects to produce its fee setting report by May 31, 2026, and to issue early fee invoices in August 2026.
- EPR laws in Maine, Maryland, Minnesota, and Washington are currently under development. CAA will be the PRO in Minnesota and Maryland and is seeking to be the PRO in Washington. Maine has not yet started its PRO selection process.
- CAA has asked producers in Washington State to register by December 15, 2025, in order to select CAA as the state’s PRO. Producers wishing to select CAA as their Washington PRO can make this appointment in the CAA Producer Portal.
We are closely following EPR developments around the country and will continue to provide relevant updates. For more information on developing EPR laws, see our previous articles:
