SB 54 Compliance: Meet Your May 31 Deadline Today

The wait is over — and so is the runway.

On May 1, 2026, California’s Office of Administrative Law officially approved the regulations for SB 54, the Plastic Pollution Prevention and Packaging Producer Responsibility Act. The rules are in effect today, and a 30-day compliance clock is now ticking.

That means producers selling packaged goods in California have until the original May 31, 2026, deadline – latest June 1, 2026, since May 31 falls on a Sunday – to submit their 2025 annual supply and source reduction reports.

This is no longer a proposed rule or pending review. SB 54 is live.

Read on for a breakdown of the newly finalized details of SB 54, what actions you need to take before May 31, and how source reduction planning can work in your financial favor.

What You Need to Do Right Now

Every producer covered under SB 54 must take one of three actions within the next 30 days:

1. Register with Circular Action Alliance (CAA)

If you’re participating in the approved Producer Responsibility Organization (PRO), register with CAA and submit your supply data. 

2. Apply as an Independent Producer

Producers who choose to comply independently must register directly with CalRecycle and apply for Independent Producer status. This path carries significantly more administrative burden and is not the default recommendation for most brands.

3. Apply for the Small Producer Exemption

If your California revenues fall below the program’s thresholds, you may qualify for an exemption. You’ll still need to register with CalRecycle and apply through the new PEPRS portal to confirm your status.

Not sure which action to take? Now is the time to find out.

Don’t wait for the deadline. The rePurpose team is helping brands navigate SB 54 registration and reporting right now. Get compliant within 2 weeks from data collection. Schedule a call today.

The New Registration and Reporting Portal Is Open

CalRecycle has launched the Packaging Extended Producer Responsibility System (PEPRS) — the new electronic portal where producers will register, report, and submit compliance documentation. Whether you’re applying for a small producer exemption or registering as an independent producer, PEPRS is where it happens.

For all producers, now is the time to log in.

• PEPRS Portal: secure.calrecycle.ca.gov/PEPRS

CalRecycle also launched a new webpage for Producers:

• Producer Guidance Hub: calrecycle.ca.gov/packaging/packaging-epr/producerguidance

California Regulates 5,000+ Producers

SB 54 is California’s largest EPR program by a wide margin, designed to regulate an estimated 5,741 producers. To put that in context, California’s other EPR programs regulate fewer than 1,000 producers each. As of today, roughly 2,000 producers are registered with CAA. That means thousands of brands still need to get moving. 

Are you one of the 5,000+? Take our EPR obligation assessment to check today.

CA Illustrative Fee Estimates Are Released 

CAA has released illustrative fee estimates (low and high scenarios) to help producers plan and budget. Final fee rates will be published in October 2026. The fee structure has four components:

• Total Base Fee — calculated on total supplied weight, varies by material category
• Reuse Investment Fee — 4 to 10 cents per plastic component pound
• PPMF Weight-Based Fee — 17 to 25 cents per plastic component pound
• PPMF Component-Based Fee — 0.10 to 0.12 cents per plastic component unit

The plastic-specific fee components stack on top of the base fee, meaning brands with heavier plastic footprints face a meaningfully higher effective rate. This makes early data quality work and source reduction planning a genuine financial lever, not just a compliance checkbox.

CAA Published Source Reduction Incentive Guidance 

CAA has also released guidance on its Source Reduction Incentive Mechanism, and includes incentive values for use when producers are preparing their Individual Source Reduction (ISR) Plans or budgeting for next year. ISR Plans are due August 1, 2026.

Two-Tiered Bonus Program

The bonus program rewards producers for achieving reductions in the amount of plastic supplied. The program is two-tiered:

• Tier 1 Bonus — rewards any demonstrated reduction in plastic supply between your 2026 supply vs. your supply for the relevant report year. 2026 will remain the year of comparison for this bonus throughout the program plan. 
• Tier 2 Bonus — rewards any demonstrated reduction in plastic supply between your 2023 baseline and your supply in the relevant report year.

As seen in the table, CAA set the Tier 2 bonus higher than the Tier 1 bonus to motivate producers to reduce their supply below the 2023 baseline. 

PCR Content Bonus

The PCR Bonus rewards the use of post-consumer recycled (PCR) content. It’s calculated as a per-pound bonus on APR-certified PCR content above your 2023 baseline. Although CAA will still only be able to claim 8% of PCR towards targets, they will not limit the amount of plastic PCR use that individual producers may claim for the bonus. After all, the use of PCR content supports CAA’s efforts to meet overall recycling targets.
Reuse Bonus

The Reuse & Refill Bonus provides a per-pound credit for single-use plastic avoided through qualifying reuse programs. This may look like plastic weight avoided via business-to-business prefill, business-to-consumer prefill, and business-to-consumer in-store refill.

Maluses to Discourage Plastic Use

Maluses are financial penalties used to discourage plastic use. These maluses raise the funds to finance the bonuses. CAA’s source reduction plan implicitly contains an ongoing enforcement approach by levying a malus on all virgin plastic supplied into the California market. 

The malus on virgin plastic starts at an illustrative ~$25/ton but could climb to an estimated $500–$700/ton by 2032 as target-driven bonus payouts scale up. For brands actively working on source reduction, the ISR Plan is your opportunity to document and financially benefit from that work.

To see how these fees play out in your source reduction planning – without dozens of manual spreadsheets, rePurpose can help. 

rePurpose launches a Packaging Simulator this summer, ahead of the ISR Plan deadline, so you can instantly model the impact of packaging scenarios in real-time. See the effect of packaging changes on EPR fees, recyclability, and more. Stay ahead of your California Source Reduction compliance deadlines.   

Key Points from the Published Guidance

• Producers should use the illustrative incentive schedule to inform the forecasts in their ISR Plans in preparation for ISR Plan submission on Aug 1, 2026. CAA will provide an updated incentive schedule in October 2026, along with the 2027 fee schedule. The schedule will be implemented in 2027, and CAA will update the values annually.
  This means that these numbers are subject to change. rePurpose keeps up with these changes so you don’t have to. Forecasts are as accurate as CAA can provide – directly in our platform to help you with your ISR Plan.

• The bonus is financed through malus fees that are spread across all plastic producers uniformly as a disincentive for not achieving source reduction.
  Be on the bonus side, not the malus side. We’ll help you get there.

• CAA recognizes prior effort for producers who reduced plastic between 2013 and 2022. They will automatically receive fee relief on those removed pounds when supply reports are filed.
  rePurpose will ingest your historical data as well as your supply data to make sure your California EPR reports (baseline, supply, and source reduction) reflect your plastic reduction efforts.
  

Key Dates for California EPR Reporting

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Tight on time? You’re not alone. We’re cutting processes that take 2+ months down to 2 weeks. We’ll streamline EPR reporting to get you compliant by May 31. Talk to our team today.

Bottom Line

SB 54 is no longer on the horizon. It’s here. California has activated the largest packaging EPR program in U.S. history to set the gold standard for reducing plastic waste. The compliance window is measured in days, not months.

For most brands, the path forward is clear: register with CAA, prepare your 2025 supply data, and start thinking seriously about your source reduction plan.

If your team needs support with any of it — from data collection and gap-filling to CAA registration and ISR planning — rePurpose is built for exactly this moment.

Schedule a call with rePurpose Global.

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