Circular Action Alliance (CAA), the producer responsibility organization implementing California's packaging extended producer responsibility (EPR) law (SB 54), has recently submitted its program plan to the state. Here is what companies should know:

• The framework for producer compliance is more defined: CAA’s program plan outlines how California's packaging EPR program would operate, including producer compliance, source reduction, recycling, reuse, and investments in recycling infrastructure. The proposal is now open for public comment through August 14 before further state review.
  
  
• Estimated program costs have been released: The draft plan projects a program budget of up to $1.87 billion in 2027, with total costs estimated between $9.35 billion and $17.2 billion over the program's first five years, according to Packaging Dive. CAA has also begun producer data collection, infrastructure planning, and released preliminary producer fee estimates to help companies prepare.
  
  
• A legal challenge has been filed: On June 22, a 17-state coalition led by Nebraska Attorney General Mike Hilgers filed a federal lawsuit seeking to block enforcement of SB 54 while the case proceeds, arguing the law places an undue burden on interstate commerce.

The Toy Association continues to monitor developments related to California's packaging EPR program and has resources available to help members understand compliance obligations and implementation timelines. Members seeking additional information or guidance should contact Lindsey Hueer, senior manager of state government affairs (Western states).

The Toy Association will continue to keep the industry apprised of developments regarding state regulations. For more information on The Toy Association’s advocacy initiatives at the state level or to join the State Government Affairs Committee, members may contact Charlotte Hickcox, director of state government affairs (Eastern states) and Lindsey Hueer, senior manager of state government affairs (Western states).