California Releases Draft Rules for Landmark Packaging EPR Law

September 2, 2025 | The California Department of Resources Recycling and Recovery (CalRecycle) formally published proposed regulations for Senate Bill 54 (SB 54), also known as the Plastic Pollution Prevention and Packaging Producer Responsibility Act, and opened a 45-day public comment period.

The Toy Association is developing comments on behalf of the industry and will submit them to CalRecycle by the October 7 public comment deadline. Toy companies that wish to have their input incorporated are encouraged to send their feedback by September 19 to The Toy Association’s Lindsey Hueer, senior manager of state government affairs.

As part of the rulemaking process, CalRecycle will host a hybrid public hearing at 10 a.m. (PT) on October 7 at the Byron Sher Auditorium in Sacramento (no registration is required to participate in person), with options to participate via Zoom or webcast. The hearing will conclude once all public comments have been submitted.

The newly released draft rules closely mirrors a version circulated earlier this summer, leaving many operational details unresolved. Key program functions will ultimately be managed by the Circular Action Alliance (CAA), the producer responsibility organization designated to implement SB 54, meaning that significant questions remain about how the law will work in practice.

SB 54 is the largest comprehensive packaging EPR program in the country. Signed in 2022, the legislation requires companies to make all single-use packaging recyclable or compostable, recycle at least 65 percent of it, and reduce overall plastic packaging by 25 percent by 2032. It also shifts the financial responsibility for waste management from consumers and local governments to producers.

The Toy Association will continue to monitor the rulemaking process and provide updates to members as the regulations take shape. Any questions may be directed to The Toy Association’s Charlotte Hickcox and Lindsey Hueer.