Packaging Compliance & Sustainability
California’s new packaging laws now apply to many small and mid-size businesses that sell into the state, not just big brands. Here is what SB 54 and SB 343 require in plain language, the key dates, and how a fixed-fee Packaging Compliance Readiness engagement gets you organized.
For food & produce, consumer packaged goods, e-commerce sellers, importers, and distributors.
The two laws, in plain language
SB 54: who pays for packaging after it’s used
The Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54, 2022) is an extended producer responsibility (EPR) law. It makes “producers” of single-use packaging and plastic single-use food service ware responsible for that material after consumers throw it away. In practice, producers must register, report packaging data every year, pay fees to fund recycling and composting, and contribute to statewide plastic-reduction and recyclability targets. Most producers comply by joining the state-approved producer responsibility organization (PRO), Circular Action Alliance (CAA).
SB 343: what you can say on the label
SB 343 (2021), often called the “truth in labeling” law, says the chasing-arrows symbol, the word “recyclable,” or instructions to recycle are deceptive unless the product or package meets California’s recyclability criteria. Those criteria rely on CalRecycle’s statewide study of what is actually collected and sorted for recycling. The rules apply based on when the item was manufactured, not when it is sold.
Permanent regulations took effect May 1, 2026. Registration was due June 1, 2026, and CAA has submitted its producer responsibility plan for CalRecycle review.
SB 343 restrictions apply to items made after October 4, 2026; Attorney General enforcement is paused by a preliminary court order while the case continues.
Sources: CalRecycle SB 54 · SB 54 regulations · CalRecycle SB 343
Are you a “producer”?
SB 54 follows the brand, not just the factory. Responsibility generally falls in this order:
1. Brand owner that makes the product
The company that manufactures the product and owns or licenses the brand or trademark it is sold under in California.
2. Brand owner or exclusive licensee
If the manufacturer is not in California, the owner of the brand, or the exclusive licensee if the owner is out of state.
3. Seller, distributor, or importer
If neither is in California, the business that sells, distributes, or imports the product into the state, which often means distributors, importers, and online sellers.
Commonly affected small & mid-size businesses
- Food & produce: branded packers, processors, and value-added products (clamshells, bags, film, trays, cartons, labels)
- Consumer packaged goods: emerging and regional brands selling through California retail
- E-commerce: product packaging plus the boxes, mailers, and fill used to ship orders to California customers
- Distributors & importers: when the brand owner has no presence in California
Exemptions and exclusions to check
- Small producer exemption: under $1 million in California gross annual sales; you must register and apply. It is not automatic, and the 2032 recyclable/compostable goal still matters.
- On-farm agricultural exclusion: growers that produce, harvest, and pack a commodity on the site where it was grown are not producers.
- De minimis components and certain food and agricultural packaging with a federal-rule conflict (by notice to CalRecycle).
Deadlines and targets
SB 54’s source-reduction and recycling targets are statewide and met collectively through the PRO, but every producer’s data, fees, and packaging choices feed into them.
- April 4, 2025SB 343
CalRecycle publishes the SB 343 Material Characterization Study (Final Findings), the starting point for which materials can be called recyclable in California. Updates to Table 2 followed in 2025 and June 2026; a full study update is due in 2027.
- May 1, 2026SB 54
CalRecycle’s permanent SB 54 regulations take effect, and the PEPRS producer portal launches.
- June 1, 2026SB 54
Producers had to register with Circular Action Alliance (the approved PRO), apply to CalRecycle as an independent producer, or apply for the small producer exemption.
- Mid-2026SB 54
Baseline (2023) and annual supply data reports and individual source-reduction plans were due to Circular Action Alliance; early fees were invoiced.
- October 4, 2026SB 343
Recyclability-claim restrictions apply to products and packaging manufactured after this date. Attorney General enforcement is currently on hold under a July 14, 2026 preliminary injunction.
- October 13, 2026SB 54
Circular Action Alliance submitted its producer responsibility plan to CalRecycle for review and public comment.
- January 1, 2027SB 54
Statewide target: 10% less single-use plastic packaging. 2027 producer fees invoiced (January and July). Updated covered material categories list due.
- January 1, 2028SB 54
30% of plastic covered material recycled.
- January 1, 2030SB 54
20% less single-use plastic; 40% of plastic covered material recycled.
- January 1, 2032SB 54
25% less single-use plastic; 65% of plastic covered material recycled; 100% of covered packaging and plastic food service ware recyclable or compostable.
Sources: CalRecycle Producer Guidance · SB 54 bill text (PRC §42050, §42057) · CalRecycle SB 343 · Circular Action Alliance. Dates can change; confirm current details with CalRecycle.
Also note: CalRecycle reports that expanded polystyrene (EPS) food service ware did not meet SB 54’s required 25% recycling rate, so producers may not sell or distribute it in or into California.
Packaging Compliance Readiness
A fixed-fee engagement led by a CPSM-certified supply chain director who manages packaging and vendor relationships for a California fresh-produce grower-shipper every day.
Packaging inventory & data
Build a SKU-level inventory of every packaging component, material, and weight, pulled from specs, suppliers, and samples, and organized for California reporting.
Producer & covered-material determination
Work through who the producer is for each product line, which packaging is covered, and which exemptions or exclusions may apply.
PRO registration & reporting readiness
Check your Circular Action Alliance or CalRecycle status, set up repeatable reporting templates, and estimate fees from the published schedule.
SB 343 label & claim review
Review artwork for chasing arrows, “recyclable” claims, and recycling instructions, and flag what to change at the next print run.
Source reduction & alternatives roadmap
Right-size, lightweight, switch materials, or move to reusable formats. I source and qualify packaging suppliers and compare total cost, including EPR fees.
Packaging Compliance Readiness
Contact for a quote
Scoped after a free 30-minute call, based on your SKU count and sites. Can be added to a Fractional Advisor or Director retainer.
Request a quoteThe SB 54 Compliance Playbook for California Food & Agricultural Producers
A plain-language, 22-page PDF guide plus a working 6-tab Excel packaging data file, written from firsthand experience completing CAA registration, packaging data reporting, and the food & agricultural exclusion filing at a California grower-packer-shipper.
- How to tell if you’re the “producer,” including private label and out-of-state supplier situations
- Step-by-step CAA registration and PEPRS exclusion filing sequence
- Building your packaging data file, including tertiary packaging (pallet wrap, case labels) and roll stock weights
- Excel template with California allocation memo, low/high fee exposure estimator, and deadline tracker
- Full deadline calendar through 2032 and the 11 most common mistakes
Five things to do this quarter
Confirm your status
Producer, small producer, excluded, or not covered, product line by product line.
Check registration
Make sure you are registered with CAA or CalRecycle, or have applied for an exemption.
Build packaging data
Component, material, and weight for every SKU sold into California.
Audit your labels
Find chasing arrows and recyclability claims on packaging made after October 4, 2026.
Plan reductions
Target the highest-fee, hardest-to-recycle plastics first, with your suppliers.
Why it pays off
- Avoid selling non-compliant product into California
- Lower EPR fees by reporting accurately and choosing recyclable materials
- Packaging cost savings from right-sizing and supplier re-bids
- Clear answers for retail customers asking about sustainability and packaging data
SB 54 & SB 343 FAQ
Am I a “producer” under SB 54?
Usually the producer is the company that makes the product and owns or licenses the brand it is sold under. If that company is not in California, responsibility can fall to the brand owner or exclusive licensee, and then to the business that sells, distributes, or imports the product into California. Packaging added to ship e-commerce orders can create its own obligation. CalRecycle publishes an “Are You a Producer?” screening tool, and the readiness engagement starts by working through it SKU by SKU.
Is there a small business exemption?
Yes, but it is not automatic. Producers with less than $1 million in gross annual sales in California may apply to CalRecycle for a small producer exemption from most reporting and fee requirements. You have to register in CalRecycle’s PEPRS portal and apply with proof of California sales. CalRecycle notes that small producers still need to plan for all of their packaging to be recyclable or compostable by 2032.
We grow and pack our own produce. Are we covered?
The law excludes a person who produces, harvests, and packages an agricultural commodity on the site where it was grown or raised. Packing at a separate facility, packing product from other growers, or selling branded value-added products can change the answer, so confirm against your actual operations.
I missed the June 1, 2026 registration date. What now?
Act promptly. Registration through Circular Action Alliance (or with CalRecycle as an independent producer, or for the small producer exemption) was due by June 1, 2026 for existing producers. Under the regulations, businesses that become producers later have a set window to register. Getting your packaging data organized is the first step either way.
Can I still use the chasing-arrows symbol?
Under SB 343, the chasing arrows or any “recyclable” claim is considered deceptive unless the material meets California’s recyclability criteria, which are informed by CalRecycle’s material characterization study. The restrictions apply to products and packaging manufactured after October 4, 2026. In July 2026 a federal court preliminarily blocked the Attorney General from enforcing SB 343 while litigation continues, but the law has not been repealed, and SB 54 relies on the same recyclability criteria. Reviewing labels now is the lower-risk path.
How much will SB 54 cost my business?
Fees depend on the type and weight of packaging you report. Circular Action Alliance has published a preliminary 2027 California fee schedule, with rates by material and adjustments for recyclability. The readiness engagement builds your packaging data and estimates fees from the published schedule, so you can budget and find savings.
Is this legal advice?
No. This is an operational and supply chain readiness service. For legal interpretation of SB 54, SB 343, or their regulations, consult qualified counsel.
Official sources
- CalRecycle: SB 54 Plastic Pollution Prevention and Packaging Producer Responsibility Act
- CalRecycle: Producer Guidance (targets, PEPRS, screening tool)
- CalRecycle: Exemptions and Exclusions
- CalRecycle: SB 54 permanent regulations
- California Legislature: SB 54 bill text
- CalRecycle: SB 343 Accurate Recycling Labels
- California Legislature: SB 343 bill text
- Circular Action Alliance: producer resources
This page is general information, not legal advice, and reflects publicly available information as of October 2026. SB 54 and SB 343 requirements, deadlines, fees, and court rulings may change. Confirm current details with CalRecycle, Circular Action Alliance, or qualified legal counsel before making compliance decisions.
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