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ARTICLE · 23 APRIL 2026

California’s Packaging EPR Deadlines Are Approaching: What Producers Need To Know About Source Reduction Reporting

Beveridge & Diamond, P.C.
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Despite delayed implementing regulations, Circular Action Alliance (CAA), the producer responsibility organization (PRO) responsible for administering California’s packaging extended producer responsibility (EPR)...

United StatesEnvironment
Allyn L. Stern
Allyn L. Stern
Kirstin Gruver
Kirstin Gruver
Nicole J. Waxman
Nicole J. Waxman
Alexander Y. Daniel
Alexander Y. Daniel

Key Takeaways

What Happened? Despite delayed implementing regulations, Circular Action Alliance (CAA), the producer responsibility organization (PRO) responsible for administering California’s packaging extended producer responsibility (EPR) program under SB 54, has set compliance deadlines for SB 54’s source reduction reporting requirements. In addition to annual supply reporting, producers must also comply with three separate source reduction reporting obligations, including the requirement to submit individual source reduction plans, which CAA has stated will be due no later than August 1, 2026, with the most up-to-date information on the corresponding deadlines described in detail below.

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