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ARTICLE · 16 JUNE 2026

Environmental Groups Challenge California’s SB 54 Plastics Regulations

Jones Day
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Three major environmental organizations have filed suit against CalRecycle, alleging that final regulations implementing California's SB 54 Plastic Pollution Prevention Act improperly weaken the statute's plastic-reduction and recycling mandates through regulatory carve-outs.

United StatesEnvironment

On June 2, 2026—one day after producers were required to register or seek an exemption—three major environmental organizations sued CalRecycle in San Francisco Superior Court, challenging final regulations implementing SB 54, California's Plastic Pollution Prevention and Packaging Producer Responsibility Act. The petitioners contend that CalRecycle failed to implement SB 54 faithfully and instead adopted regulatory carve-outs that weaken the statute's plastic-reduction and recycling mandates.

Key Allegations

Petitioners allege that the final regulations depart from SB 54 in four principal respects:

  • Hazardous-waste standard. SB 54 uses a quantity-based hazardous waste exclusion, focused on how much hazardous waste a technology generates. The regulations allegedly substitute a risk-of-harm inquiry with no numeric threshold and treat any hazardous waste managed under a valid permit as posing no substantial risk—so a permitted facility can qualify as recycling regardless of the

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