CalRecycle has published updated compliance tools and guidance under the Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54). The law shifts the financial and operational responsibility for managing single-use packaging and plastic food service ware onto the companies that manufacture, import, or sell packaged products in California.
Key Statutory Targets & Timeline
To remain compliant in the California market, covered packaging must meet progressive source-reduction and recycling mandates:
- Jan 1, 2027: Achieve a 10% reduction in single-use plastic packaging.
- Jan 1, 2028: Achieve a 30% recycling rate for single-use plastic.
- Jan 1, 2030: Achieve a 20% reduction in plastic & 40% recycling rate.
- Jan 1, 2032:
- Achieve a 25% reduction in single-use plastic.
- Achieve a 65% recycling rate for single-use plastic.
- 100% of single-use packaging and plastic food service ware must be recyclable or compostable.
Who is Considered a “Producer”?
Under SB 54, the obligations fall on entities selling or distributing packaged goods in California. In general, the order of responsibility is:
- The brand owner or licensee of the packaged product in California.
- If the brand owner is not in California, responsibility falls on the importer or distributor bringing the packaged product into the state.
Note: Small business exemptions, categorical exclusions (such as certain primary agricultural/food packaging notices), and specific material exemptions may apply depending on annual revenue and packaging volume.
Compliance Options: How Seafood Businesses Must Comply
All covered producers must submit registration, packaging baseline data, and compliance reports through CalRecycle’s PEPRS (Packaging Extended Producer Responsibility System) portal via one of three paths:
- Join the Approved Producer Responsibility Organization (PRO): Joining Circular Action Alliance (CAA) – California’s designated PRO – allows businesses to delegate plan development, fee collection, and aggregate reporting requirements.
- Independent Producer Path: Comply individually by submitting an independent plan directly to CalRecycle proving compliance with all source-reduction and recycling thresholds.
- Small Producer Exemption: Apply for official exemption status if your business meets state threshold qualifications.
Why This Matters for Seafood Processors, Distributors & Retailers
- Audit Seafood Packaging Types: Evaluate all primary, secondary, and transport packaging used for fresh, frozen, or value-added seafood shipped into or within California (e.g., plastic trays, films, vacuum pouches, plastic totes, and EPS/Styrofoam shipping coolers).
- Review EPS Restrictions: Expanded Polystyrene (EPS) containers face rigorous separate compliance and recycling benchmarks under SB 54 – alternative recyclable or compostable packaging choices should be evaluated now.
- Upstream/Downstream Data Alignment: Seafood processors and distributors will face requests from retail and food service clients to provide exact material compositions and weights for all product packaging.
For tools including the Producer Screening Tool, Reporting Guidance, and registration details, visit the CalRecycle Producer Guidance Portal or contact Packaging@calrecycle.ca.gov.