Tox of the Town
SB 54 Update: California Releases New Guidance Documents for Plastic & Packaging EPR Law
by Sedina L. Banks, Sherry E. Jackman, and Bryce Lourié
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.
For more information on SB 54, see our previous articles Moving Targets: Multi-State EPR Packaging Laws—Key Updates & Deadlines and CalRecycle Releases Latest Draft of Regulations for California’s Plastic & Packaging EPR Law.
* On September 8, 2025, CalRecycle updated this document to correct typos in the Description and Examples column in Table 1 for CMCs 25 PF10N and 25 PF10P and also provide additional clarity in 25 PF17P*. This article has been updated with the new document.
