Question 1

Who has to comply with California SB 54?

Accepted Answer

Any producer that sells, ships, imports, or distributes products in single-use packaging or plastic single-use food service ware to California consumers must comply with SB 54. This includes brands selling online into California, even if their headquarters are out of state.

Question 2

When is the SB 54 producer registration deadline?

Accepted Answer

Producers must register with the Circular Action Alliance, apply as an independent producer, or claim the small producer exemption by June 1, 2026. Full implementation begins on January 1, 2027.

Question 3

Does SB 54 cover non-plastic packaging?

Accepted Answer

Yes. SB 54 applies to all single-use packaging, including glass, metal, paper, and multi-material formats. You report each material separately under SB 343 recyclability standards.

Question 4

What is the SB 54 small producer exemption?

Accepted Answer

Producers below the small-producer revenue threshold may qualify for a reduced compliance pathway. Eligibility must be confirmed with CalRecycle prior to the registration deadline.

Question 5

How does PCR content affect SB 54 compliance?

Accepted Answer

Higher post-consumer recycled (PCR) content reduces per-unit fees and helps producers progress toward the 2032 milestone of 25% plastic source reduction. AB 793 already requires 25% PCR in beverage containers by 2025 and 50% by 2030.

Question 6

Do you sell packaged products in California?

Accepted Answer

This includes products sold online that ship to California addresses.

Question 7

What is your primary packaging material?

Accepted Answer

Select the main material. SB 54 covers ALL single-use packaging, not just plastic.

Question 8

What is your estimated annual revenue from products sold in California?

Accepted Answer

This helps determine if you qualify for the small producer exemption.

Question 9

Is your current packaging recyclable?

Accepted Answer

Under SB 54, ‘recyclable’ means genuinely collected and processed in California, not just carrying a recycling symbol.

Question 10

Does your packaging contain post-consumer recycled (PCR) content?

Accepted Answer

AB 793 requires 25% PCR in beverage containers by 2025, 50% by 2030.

Do you need to register for SB 54?

Do you sell packaged products in California?