California SB 54: Status After Nov 2025 Reporting

California SB 54: Status After Nov 2025 Reporting

By Kevin Kai Wong, Managing Partner at gCurv Technologies

California's SB 54 packaging EPR program reached a meaningful inflection point in late 2025. The November 15, 2025 data submission, which used 2023 baseline data, was the last voluntary milestone before the program shifted toward formal rulemaking and CAA's program plan review. As of August 22, 2026, the confirmed timeline is clearer than it was a few months ago: CalRecycle finalized the SB 54 implementing regulations on May 1, 2026, Circular Action Alliance submitted its draft Program Plan on June 15, 2026, and the SB 54 Advisory Board's comment period closed on August 14, 2026.

This post lays out the confirmed timeline, what the November 2025 reporting cycle covered, what happens next, and how producers should prepare. If you need broader context on SB 54's structure, fee tiers, and long-term mandates, our California SB 54 EPR Compliance Guide covers the full program.

The confirmed SB 54 timeline after November 2025

• November 15, 2025: producers submitted 2023 baseline data to CAA. CalRecycle treated this as voluntary, but it supported program planning and baseline development.

• May 1, 2026: CalRecycle finalized the SB 54 implementing regulations, the rulemaking process that had been restarted in March 2025 concluded.

• June 15, 2026: CAA submitted its draft Program Plan to the SB 54 Advisory Board, opening a public comment period.

• August 14, 2026: Advisory Board written comment deadline on the draft Program Plan. As of today, August 22, 2026, this deadline has passed.

• On or before January 1, 2027: CalRecycle approves the final Program Plan and the SB 54 program formally begins.

• March 1, 2027: first Plastic Pollution Mitigation Fund (PPMF) fees due from producers.

• July 1, 2027: first administrative fees due to CalRecycle.

The "May 31, 2026" date that has circulated in some coverage is not part of CalRecycle's or CAA's confirmed SB 54 timeline. It appears to have been misapplied from Maryland's own May 31, 2026 deadline under SB 901. For California, the relevant 2026 milestones are the confirmed dates above.

What the November 15, 2025 cycle covered

The November 15, 2025 submission was a data-only milestone, not a fee-triggering event. Producers reported 2023 packaging data through CAA's portal to help establish the baseline for source reduction targets and program planning. CalRecycle treated it as voluntary, and it did not directly determine fees.

This matters because the next formal reporting cycle will be governed by the regulations finalized on May 1, 2026 and the approved program plan. Producers should not assume the November 2025 format or timeline repeats exactly.

The Program Plan review: June 15 to August 14, 2026

CAA's draft Program Plan, submitted June 15, 2026, defines how fees will be collected, how recycling infrastructure investments will be directed, and how enforcement will operate once the program launches. The Advisory Board's comment period closed August 14, 2026.

The plan will reflect the data producers submitted, including the November 2023 baseline and any subsequent CAA collections. That means the accuracy of your reported data influences the plan's assumptions about total packaging volume, material mix, and recyclability rates. Inaccurate inputs create a program plan built on unreliable assumptions, which affects fee schedules and targets for all participants.

Fee milestones: 2027 and beyond

After the Program Plan is approved, California SB 54 fees arrive in two phases.

• March 1, 2027: first Plastic Pollution Mitigation Fund fees due to CAA. These are distinct from the ongoing administrative fees.

• July 1, 2027: first administrative fees due to CalRecycle.

These dates are tied to the program's formal launch on January 1, 2027. The exact fee amounts will depend on the approved plan's eco-modulation framework, material categories, and recyclability classifications.

What producers should do now

1. Confirm CAA registration and your Participant Producer Agreement. You cannot report or pay fees without it.

2. Maintain clean SKU-level packaging data for California. Material category, weight, recyclability under CalRecycle's CMC list, and recycled content documentation should be queryable.

3. Review the draft Program Plan and any Advisory Board comments published by August 14, 2026. The final plan will define your fee methodology.

4. Prepare for the first formal reporting cycle under the approved program plan. The specific format and due date will be set by CAA and CalRecycle, not by the voluntary November 2025 template.

5. Budget for the March 1, 2027 and July 1, 2027 fee milestones.

Related reading

• California SB 54 Explained: The Packaging EPR Law Reshaping CPG in 2026

• California AB 2611 Explained: Marine Degradable Claims and Packaging Labels

• Seven US States with Active Packaging EPR in 2026: A Status Map

Primary sources: Circular Action Alliance California and CalRecycle's SB 54 program page. Confirm all dates directly with these sources before acting.

Content reviewed by Kevin Kai Wong, Managing Partner at gCurv Technologies.