California’s Sweeping Packaging Law Under SB 54: Status Update And Litigation Overview

California's SB 54, known as the Plastic Pollution Prevention and Packaging Producer Responsibility Act, was signed into law on June 30, 2022, and became legally effective on January 1, 2023, with final permanent regulations approved on May 1, 2026. It is widely regarded as among the most ambitious extended producer responsibility (EPR) laws in the United States for single-use packaging and plastic food service ware. The statute sets strict mandates, requiring producers to reduce plastic use, ensure packaging is recyclable or compostable by 2032, and meet escalating recycling rates—culminating at 65% for plastic by 2032.

Broad Overview of the Framework

Under SB 54, producers must join or form a Producer Responsibility Organization (PRO) or demonstrate individual compliance. The PRO leads coordination of fees, infrastructure investments, packaging design initiatives, source reduction, and recycling activities. The law imposes significant financial and operational obligations on