Circular Action Alliance (CAA), the approved PRO for California’s Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54) which covers single-use packaging and plastic food service ware, has set November 15, 2025, as the deadline for submitting the first report.
Even though some SB54 implementation regulations continue to be reviewed and revised, reporting will begin. CAA must gather data to create a baseline to better understand the scope and volume of covered packaging, track compliance with source reduction goals, and set fees.
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Obligated Producers were to have registered with CAA by September 5, 2025, and will need to make sure this is completed to be able to submit their reports.
What will be needed for the report?
• 2023 data
• total supplied weight in pounds (lbs.)
• weight of plastic components in pounds (lbs.)
• the number of plastic components supplied (count)
Fees
After reports have been submitted, and the PRO fee plan has been completed, Producers will be assessed fees. Payment of this fee will not be required until 2027. Fees will thereafter be assessed annually, and payable to the PRO.
Key Dates
• September 5, 2025 – Producer registration deadline
• September 23, 2025 – CAA portal open for reporting of 2023 data
• November 15, 2025 -Deadline for submitting 2023 packaging supply data to CAA
• January 1, 2027 – Fee payments for the program begin
Next steps
Confirm obligations:
- Does your company put or bring covered materials into California?
- Is your company a Producer?
Register:
- Have you registered with CAA?
- And signed their California Interim State Addendum (CAISA)?
Gather data:
- Calendar year 2023 data
- Total packaging weight in pounds (lbs.)
- Weight of plastic components in pounds (lbs.)
- Number of plastic components supplied (count)
- Remember to include primary, secondary, and tertiary packaging
Submit Data:
- Submit 2023 data through CAA’s portal
Pay Fees:
- After a report has been submitted and the EPR plan is finalized, fee payments will commence in 2027
Penalties: Noncompliance may result in fines of up to $50,000 per day, per violation
CGlobal, the EPR consulting division of H2 Compliance, can help you navigate the complexities of these and other EPR reporting requirements. Let us help you develop a robust compliance strategy to meet the new reporting regulations, manage your product’s lifecycle, and navigate the packaging EPR landscape smoothly. Contact CGlobal today to ensure you stay compliant and ahead of the curve.
Published October 6th, 2025