Who Is the Responsible Party? Navigating Ambiguity Under SB 54
The roar of the crowd, the intensity of the match, and the mountains of plastic packaging waste left behind, often left in the periphery when the game is over.
As Los Angeles hosts matches during the 2026 World Cup, as one of the largest tournaments in soccer history, the scale of material consumption reaches new levels. Match-day memorabilia and consumables such as beverages, alcoholic drinks, popcorn, hotdogs, sweets, and merchandise generate large volumes of packaging and food service-ware throughout the month of the tournament.
With SB 54 now in effect, the final whistle no longer ends the producer’s responsibility, marking the end of the status quo where single-use plastic waste is treated as an unregulated side effect.
The Invisible Obligation
At stadium events, several parties contribute to the overall material waste footprint:
- Companies supplying packaged beverages and snacks
- Food brands whose packaging enters the stadium supply chain
- Concessionaires preparing and serving food on-site
- Venue operators deploying private-label, custom, or branded packaging
Under SB 54, each covered material has one legally defined “producer”, determined through a strict statutory hierarchy based on brand ownership, licensing, and ultimately sale or distribution into California.
While multiple parties may appear involved commercially, the law assigns responsibility to a single defined producer per material, based on this hierarchy.
This creates a cascading responsibility model.
In practice, this means that liability does not sit with all parties simultaneously. It is assigned to one entity per material, determined by the order of the statutory definition.
Where the Real Exposure Lies
High-profile events like the World Cup highlight a common misconception: that large, branded products account for most of the regulatory exposure.
In reality, a substantial share of stadium material flows may come from:
- Unbranded food service items
- Single-use cups, trays, wrappers, and utensils
- Private-label or venue-specific food offerings
- Items prepared and consumed on-site
These materials fall within the scope of SB 54 as single-use packaging and food service ware.
Because many of these items lack a clear upstream brand owner, responsibility may frequently fall to the concessionaire or entity selling/distributing the product in California.
This is not because these parties “handle” the packaging, but because, in the absence of a qualifying brand owner or licensee, the statutory definition assigns producer status to the seller or distributor into the state.
This is where ambiguity becomes operational risk: the most visible brand is not always the legally responsible producer.
The Waste Reality
At an event like a World Cup match in Los Angeles, the result is a waste stream that is often:
- Heavily contaminated with food residue
- Difficult to sort or recycle effectively
- Predominantly directed toward disposal rather than recovery
This creates a direct compliance risk under SB 54, which extends beyond recyclability in theory to the broader requirement for waste reduction and improved recovery outcomes.
For obligated producers, this is now a regulated compliance requirement.
Moving to Source Reduction: The Operational Shift
At the heart of SB 54 is a clear directive: reduce the amount of plastic placed on the market.
For stadium environments, this aims to change how products are delivered to consumers.
Traditional model
- Single-use packaging dominates
- Waste is treated as a by-product
- Responsibility is assumed to sit downstream
Source reduction model
- Packaging is eliminated where possible
- Reuse and refill systems are considered
- Material efficiency becomes a core design principle
Producer responsibility is determined upfront, before products and packaging enter the California market, and soccer fans in Los Angeles.
A System-Level Challenge
Events like the World Cup expose a critical feature of SB 54: not that multiple producers exist for a single item, but that different materials within the same venue can each have different legally defined producers.
At the stadium:
- Packaged goods may be tied to one producer
- Prepared food and service-ware may be tied to another
- Private-label or custom packaging may introduce further distinctions
Each material stream must be assessed individually
This creates risks such as:
- Gaps in reporting
- Duplicate reporting across entities
- Misallocation of compliance costs
- Incorrect identification of the legally defined producer
Contracts between parties (e.g., brand, concessionaire, distributor, venue) are critical; not because they override the law, but because they clarify who meets the statutory criteria (such as brand ownership or licensing) in practice.
Getting Started: Clarifying Responsibility
For companies involved in major venues in Los Angeles during the 2026 World Cup, the first step is clarity aligned with the SB54 requirements.
To begin:
- Map producer responsibility across all material flows
- Establish a 2023 baseline for packaging volumes placed on the California market
- Identify high-risk materials, especially those likely to be contaminated
- Align with partners on accountability
- Review contracts to confirm who qualifies as the producer under SB 54 (e.g., brand owner, licensee, or seller)
- Document producer determinations by material type, ensuring alignment with the statutory hierarchy
The Opportunity Ahead
Global events like the World Cup amplify both the visibility of waste and the scrutiny of EPR compliance.
In California, SB 54 ensures that this scrutiny translates into accountability.
For companies operating in or supplying these venues, those that move early to reduce material use, redesign service systems, and correctly identify producer responsibility will be best positioned to manage risk and respond to regulatory expectations.
CGlobal, the EPR consulting division of H2 Compliance, supports this process through detailed applicability assessments, regulatory interpretation, data analysis, registration and reporting support, and ongoing compliance program management; helping organizations move from uncertainty to a documented, defensible producer position, in line with SB54 and reducing the plastic waste generated in California.
Published June 26th, 2026