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ARTICLE · 27 JANUARY 2026

SB 54, Take Two (Again): California Pulls Packaging EPR Regulations Back For Revision

Greenberg Glusker LLP
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If California's SB 54 rulemaking process feels familiar, that's because it is. CalRecycle has withdrawn proposed implementing regulations—signaling continued...

United StatesEnvironment
Sherry E. Jackman
Sherry E. Jackman
Sedina L. Banks
Sedina L. Banks
Bryce Lourié
Bryce Lourié
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If California's SB 54 rulemaking process feels familiar, that's because it is. CalRecycle has withdrawn proposed implementing regulations—signaling continued recalibration of one of the most complex packaging Extended Producer Responsibility (EPR) programs in the country.

On January 9, 2026, California's Department of Resources Recycling and Recovery (CalRecycle), the agency overseeing California's EPR program, withdrew its proposed regulations implementing the Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54) from review by the Office of Administrative Law. This is not the first time; prior SB 54 draft regulations have also been pulled back to address stakeholder concerns and technical issues before moving forward. We blogged about it here.

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