What is the California SB 54 compliance deadline?

Covered producers were required to register with Circular Action Alliance in 2024 and begin submitting annual packaging reports in 2025. Source-reduction targets under SB 54 phase in through 2032.

Who is the PRO for California?

Circular Action Alliance (CAA) is the single designated PRO for California SB 54. CalRecycle is the state regulator overseeing the program.

What packaging materials are covered under SB 54?

SB 54 covers single-use packaging and plastic food-service ware: rigid and flexible plastics, paper/fiber, glass, metal containers, and compostables. Certain durable and reusable items are excluded.

What is the California de minimis threshold?

Producers with less than approximately $1M in global gross revenue from covered products sold in California are generally exempt. Consult CAA guidance for exact applicability.

Where do I register as a California producer?

Register directly with Circular Action Alliance at circularactionalliance.org. CalRecycle maintains program rules and enforcement authority at calrecycle.ca.gov/packaging/.

California SB 54

How much will California SB 54 cost your brand?

Paste your Shopify URL. In 60 seconds you'll see a per-SKU estimate of your annual California packaging fee.

Estimate my CA liability See fee schedule

Covers CA SB 54, CO HB 22-1355, ME LD 1541, and OR SB 582

Rates pulled from PRO guidance, refreshed quarterly

No signup. Results in under a minute.

Built for $10M to $100M brands on Shopify

What is California SB 54?

SB 54, the Plastic Pollution Prevention and Packaging Producer Responsibility Act, was signed by Governor Newsom in June 2022. It is the most aggressive packaging EPR statute in the country and the first to set hard source-reduction targets. By 2032, all single-use packaging and plastic food-service ware sold in California must be recyclable or compostable, with 25% plastic reduction by weight and a 65% recycling rate.

SB 54 is not a sales tax. It is an annual, material-specific fee on every producer (the brand owner or importer) that puts covered packaging on the California market. Fees are set and collected by the state's Producer Responsibility Organization, Circular Action Alliance (CAA), which CalRecycle approved as the single PRO. Registration was required in 2024, and the first annual packaging reports were due in 2025.

SB 54 uses eco-modulation. Fees go up for hard-to-recycle formats (multilayer flexibles, carbon-black PET, certain laminates) and down for recyclable or post-consumer-recycled packaging. Two brands shipping the same tonnage into California can end up paying very different fees based on material choices. CalRecycle can audit producers and levy penalties for non-compliance.

If your brand does more than roughly $1M in California-attributable revenue on covered products, you are a covered producer. Out-of-state DTC brands are included: SB 54 follows the packaging, not the seller's tax nexus.

Who must comply

If your brand sells packaged consumer goods into California and clears the state's de minimis threshold, you are a covered producer under SB 54. California applies to producers with more than $1M in annual gross revenue from covered products sold into California. Out-of-state DTC sellers are included. A physical tax nexus is not required.

Administered by Circular Action Alliance.

Covered materials and example rates

Rates below are modeled from PRO public guidance (2025-01-01). Actual rates are set annually and subject to change.

Material	Rate (USD / metric ton)
Rigid plastic	$850
Flexible plastic and film	$1,250
PET bottles	$620
HDPE bottles	$620
Corrugated fiber	$180
Paperboard and cartons	$240
Glass	$120
Aluminum	$90
Steel	$95
Multi-material / laminates	$1,100
Compostable packaging	$450

Deadline

SB 54 timeline: Producer reporting started in 2025. First CAA invoices land in Q4 2025.

How we estimate your fee

1
Extract your packaging

We read your Shopify storefront (or product URLs you provide) and identify every SKU with its likely packaging components: bottles, caps, cartons, mailers, labels, and inserts.
2
Apply California rates

For each material family, we multiply estimated tonnage sold into California by the SB 54 per-metric-ton fee published by Circular Action Alliance.
3
Return a ±20% band

You get an annual fee range (low / mid / high) with a per-material breakdown you can hand to your ops or compliance team.

Example calculation

A $25M DTC skincare brand shipping 400k glass-bottle-and-carton units/year in California

Estimated fee: $18,000 – $27,000 / year

Estimates shown with a ±20% confidence band. Not audit-grade; for informational use.

Read the full text of SB 54 on the official California Department of Resources Recycling and Recovery (CalRecycle) site: https://calrecycle.ca.gov/packaging/

California SB 54: frequently asked questions

What is the California SB 54 compliance deadline?

Covered producers were required to register with Circular Action Alliance in 2024 and begin submitting annual packaging reports in 2025. Source-reduction targets under SB 54 phase in through 2032.
Who is the PRO for California?

Circular Action Alliance (CAA) is the single designated PRO for California SB 54. CalRecycle is the state regulator overseeing the program.
What packaging materials are covered under SB 54?

SB 54 covers single-use packaging and plastic food-service ware: rigid and flexible plastics, paper/fiber, glass, metal containers, and compostables. Certain durable and reusable items are excluded.
What is the California de minimis threshold?

Producers with less than approximately $1M in global gross revenue from covered products sold in California are generally exempt. Consult CAA guidance for exact applicability.
Where do I register as a California producer?

Register directly with Circular Action Alliance at circularactionalliance.org. CalRecycle maintains program rules and enforcement authority at calrecycle.ca.gov/packaging/.
What is Extended Producer Responsibility (EPR) for packaging?

EPR shifts the cost of managing post-consumer packaging waste from cities and taxpayers to the brands that sold the packaging in the first place. In an EPR state, the "producer" (usually the brand owner or importer) pays a per-ton fee on every packaging material it ships into the state. That money pays for recycling collection, sorting infrastructure, and consumer education.
Does my brand have to comply?

If you sell packaged consumer goods into California, Colorado, Maine, or Oregon and your revenue clears the state de minimis threshold (roughly $1M to $5M depending on the state), you are a covered producer. This includes out-of-state DTC brands. Physical nexus is not required; the fee follows the packaging, not the seller.
How is the EPR fee calculated?

Each state publishes a per-metric-ton fee for every packaging material family: rigid plastic, flexible plastic, glass, aluminum, fiber, and so on. Your fee is (tons of that material shipped into the state) × (state rate), added up across every material and every state. Our calculator reads your product pages to estimate the tonnage and applies the current rate tables.
What is a Producer Responsibility Organization (PRO) and do I need to register?

A PRO is a nonprofit appointed by the state to collect fees and run the program. California, Colorado, and Oregon all use Circular Action Alliance (CAA). Maine is different: its program is run by Maine DEP directly, with no PRO. If you are a covered producer in CA, CO, or OR, you register with CAA and submit packaging data each year.
When are the compliance deadlines?

California: producer reporting started in 2025 under SB 54. Colorado: registration was due October 1, 2024, with fees on 2025 packaging data. Oregon: compliance fees began July 1, 2025. Maine: first producer payments are due in 2026. Confirm current dates with the relevant authority before filing.
How is EPR different from a carbon tax or sales tax?

EPR is not a tax on emissions or retail sales. It is a material-specific fee assessed on the weight of packaging you put on the market in a given state, paid once a year to either the state's PRO (CA, CO, OR) or to the state agency itself (ME). The revenue goes to recycling infrastructure, not the general fund.