Regulations for California’s Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54), were approved on Friday, 1st May 2026, providing regulatory clarity for producers while confirming the reporting and implementation deadlines in effect. SB 54 is the first US Extended Producer Responsibility (EPR) program to create legislative mandates and targets that require producers to reduce the amount of plastic packaging placed on the market.
California included plastic source reduction targets in its EPR legislation to effectively manage the growing volume and concerns around plastic consumption and pollution. As covered in Eunomia’s source reduction webinar earlier this year, under SB 54, the Producer Responsibility Organization (PRO) and their members are required to source reduce single-use plastic packaging and food service ware by 25% by 2032, with interim source reduction targets in 2027 and 2030.
Now that regulations are approved, the PRO and producers have regulatory clarity to make packaging design and investment decisions to reduce plastic packaging. California Department of Resources Recycling and Recovery (CalRecycle) contracted with Eunomia to review the current source reduction context in California and to produce an accompanying analysis of the actions and investments that could be used to achieve the requirements. Eunomia led the complex analysis to provide key inputs for CalRecycle’s compulsory Statewide Needs Assessment and teamed up with specialist partners Perpetual, InterEthnica, and Touch Design.
This project follows the landmark impact assessment Eunomia carried out for DG Environment of the European Commission over a decade ago – research that informed the now active and reformative Packaging and Packaging Waste Regulations (PPWR), which covers all packaging circulating within Europe.
Sarah Edwards, circular economy expert and North America Director at Eunomia, said: “US states are no longer treating extended producer responsibility as simply a funding mechanism for recycling. California has set the pace by redesigning EPR to go further – embedding requirements that single-use packaging and single-use plastic food service ware be recyclable or compostable by 2032 and shifting investment and action higher up the waste hierarchy. The emphasis is now on placing less packaging on the market and actively building reuse systems, not just managing waste after the fact. Other states are following suit: Maine, Maryland, Minnesota and Washington have integrated source reduction and reuse‑refill in their EPR bills regulations, signalling a clear move beyond legacy EPR models.
“This is a complex area which requires critical thinking to get it right, and where, until now, there haven’t been existing solutions or pathways mapped out for policy makers or industry alike. We’re really pleased to have delivered the research to CalRecycle that will help inform producer plans to achieve these landmark source reduction targets.”
Eunomia’s evidence included:
- Additional analysis of the source reduction baseline published by CalRecycle to better understand the relative contributions of single-use plastic packaging and food service ware currently used in California, including the estimated weight and number of plastic components across over 40 product types and over 20 packaging formats
- Mapping the availability of all reuse and refill systems for consumers using GIS mapping software and an in-depth stakeholder engagement program
- Identifying source reduction strategies, pathways, and accompanying estimated costs and benefits for different packaging formats
Associated reports can be downloaded from the CalRecycle website:
- The Current State of Source Reduction Report
- An Analysis of Actions and Investments Needed to Achieve Source Reduction
Eunomia offers services to packaging producers who need help navigating SB 54, developing source reduction plans or associated policies.