California SB 54 Compliance & Packaging EPR Reporting
What businesses need to know about the Plastic Pollution Prevention and Packaging Producer Responsibility Act
California's packaging EPR requirements are in effect. Is your business prepared?
If you sell packaged products or single-use plastic food serviceware in California, SB 54 may create new reporting, data management and financial obligations for your business.
From determining your responsibilities to preparing reports and managing producer fees, Evnia helps businesses navigate California’s EPR requirements with accuracy, structure and confidence.
Talk to a California EPR Specialist
- 20+ Years of EPR Experience
- Full-Service Compliance Management
- Packaging Classification Expertise
- Regulatory & Reporting Support
Does California SB 54 Apply to Your Business?
California’s Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54) establishes requirements for producers of covered packaging and single-use plastic food serviceware.
Not every company handling packaging is necessarily the obligated producer. Responsibility depends on the legal producer definition, the product, the supply chain and applicable exclusions.
Certain small producers and materials may also qualify for exemptions or exclusions.
Not sure whether your business qualifies as a producer?
Depending on the applicable legal definition of a producer, your business may have obligations if it:
- Owns or licenses brands whose packaged products are sold in California.
- Manufactures or imports packaged products intended for the California market.
- Distributes or sells covered products in California, including through e-commerce.
- Introduces covered packaging or food serviceware into the California market.
What Do California Producers Need to Do?
SB 54 goes beyond registering with a Producer Responsibility Organization (PRO). Producers must also understand their packaging portfolio, maintain accurate data and meet applicable reporting and financial requirements.
Key responsibilities may include:
1. Determine your producer status
Identify which products and packaging fall within the program and confirm which business entity is responsible.
2. Complete applicable registration requirements
Coordinate registration and participation requirements with Circular Action Alliance (CAA) and CalRecycle, as applicable.
3. Collect and classify packaging data
Identify covered materials, determine component weights and assign the appropriate material categories.
4. Prepare and submit required reports
Compile supply data, maintain supporting documentation and address applicable source reduction and other reporting requirements.
5. Plan for producer fees
Understand how reported supply data, material classification and California’s fee schedules influence your financial obligations.
California’s permanent SB 54 regulations took effect on May 1, 2026. CAA has published its 2027 producer fee schedule as the program prepares for implementation.
What Packaging Data Do You Need for California EPR Reporting?
Packaging materials and components
- Packaging material types and composition
- Component-level weights
- Appropriate covered material categories
- Information on detachable and non-detachable components
Product and supply information
- Product or SKU references
- Quantities supplied in California
- Applicable reporting periods
- Brand ownership and producer responsibility information
Environmental and compliance information
- Post-consumer recycled content, where applicable
- Recyclability and compostability information
- Supplier documentation
- Packaging reduction, reuse and material substitution information
Collecting this information across multiple products, suppliers and business units can become a significant operational challenge.
Evnia by UL Solutions helps transform complex packaging information into structured, report-ready data.
How Evnia Helps You Manage California EPR Compliance
Whether you need comprehensive support or specialized packaging data services, Evnia offers solutions adapted to your business.
Choose between our fully customizable turnkey EPR management or the data-oriented Lab services.
Full-Service EPR Management
Let our specialists manage the complexity of California EPR compliance while your team focuses on its core responsibilities.
Our services include:
- Producer responsibility assessment: Helping identify applicable obligations and reporting responsibilities.
- Packaging data management: Collecting, organizing and validating information from internal teams and suppliers.
- Material classification: Supporting accurate assignment of packaging to applicable reporting categories.
- Report preparation and submission: Preparing reports and coordinating submission requirements.
- Fee management support: Reviewing reported data and supporting producer fee planning and payment coordination.
- Regulatory monitoring: Tracking changes to California’s EPR requirements and relevant deadlines.
- Reporting documentation: Maintaining supporting information to facilitate verification and audit readiness.
Evnia Lab: Reliable Packaging Data
Accurate packaging weights and material classifications are essential to EPR reporting.
Evnia Lab provides specialized packaging weighing and classification services to help producers improve data quality, reduce uncertainty and support consistent reporting.
Better data.
More reliable reporting.
Greater visibility into your EPR obligations.
Managing EPR Beyond California?
California is only one part of the evolving U.S. EPR landscape.
Producers operating across several states must navigate different requirements, reporting procedures, deadlines and fee structures.
Evnia by UL Solutions provides coordinated EPR compliance support across multiple U.S. programs, helping businesses manage their obligations with a consistent approach.
Frequently Asked Questions
Does SB 54 apply to companies outside California?
Potentially. Companies located outside California may have producer responsibilities if they supply covered products or packaging into the state. The applicable producer definition determines responsibility.
Are businesses with less than $1 million in annual sales exempt?
Eligible small producers with gross annual sales below $1 million may apply for exemptions from certain reporting and fee requirements. Exemptions are not automatic, and other obligations may continue to apply.
How are California EPR producer fees calculated?
Producer fees are based on reported supply data, applicable material categories and CAA’s fee-setting methodology, including program-specific adjustments. The 2027 fee schedules are available to support financial planning.
Can Evnia by UL Solutions manage our California EPR reporting?
Yes! Evnia provides full-service EPR management, including data collection, packaging classification, report preparation, submission support and regulatory monitoring.
Get Support With California SB 54 Compliance
Not sure whether your business is meeting California’s EPR requirements?
Need help preparing reports, improving packaging data or understanding your producer fees?
Evnia’s specialists can help you evaluate your obligations and determine the level of support your business needs.
Talk to a California EPR Specialist
