Circular Action Alliance California (CAA) submitted its revised California program plan to CalRecycle for review, marking a significant milestone in the implementation of California’s Plastic Pollution Prevention and Packaging Producer Responsibility Act, commonly known as SB 54.
The revised plan reflects feedback received during the 60-day public comment period led by CAA and includes significant updates intended to strengthen implementation and provide greater clarity into proposed program investments and costs.
“Submitting California’s program plan marks a major step forward in establishing a compliance pathway for producers,” said Shane Buckingham, CAA Chief of Staff. “By recognizing the unique challenges across different material categories, our plan creates a structured strategy that provides the time and framework to overcome complex technical hurdles while making steady, measurable progress towards SB 54’s recycling goals.”
How the Plan Was Strengthened
During the public comment period, CAA received over 2,400 comments from local jurisdictions, trade associations, NGOs, tribal representatives, producers, the Packaging Producer Responsibility Advisory Board and other interest holders. CAA’s revised program plan builds substantially on the draft plan submitted to the advisory board in June, with revisions made to multiple sections including environmental justice, reimbursement, materials strategy, Responsible End Markets (REMs), budget development and fee-setting.
CAA also expanded the plan’s budget and fees chapters, providing additional detail on proposed investments, anticipated costs, fee-setting methodology and how producer funding would support implementation activities over time.
“Public input has played a valuable role in strengthening this plan,” said Emily Coven, California Executive Director. “We greatly appreciate the time people and organizations took to share feedback reflecting a wide range of perspectives, and we made meaningful revisions in response. The revised plan provides greater clarity on proposed investments and implementation activities and lays out a practical path toward achieving the objectives established under SB 54.”
A public comment summary outlines major themes raised during the review process and the changes made in response.
What the Plan Will Deliver
The program plan outlines a comprehensive approach to implementing SB 54, with proposed investments and programs designed to deliver outcomes across California’s recycling and reuse system, including:
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Targeting recycling investment where it is needed most: The plan provides for significant investment in California’s recycling system, including support for rural and remote communities and a broad range of entities eligible for reimbursement.
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Supporting environmental justice: Environmental justice considerations are integrated throughout the plan, including a process to identify and consider potential environmental justice impacts during reimbursement application review.
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Increasing transparency and accountability for recycled materials: A comprehensive Responsible End Markets Standard is designed to provide greater visibility into where recycled materials go and establish consistent standards for responsible end markets.
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Advancing source reduction and recycled material use: The plan outlines strategies to reduce plastic packaging and single-use food serviceware, improve recyclability and encourage the use of post-consumer recycled materials, supporting progress toward California’s source reduction and recycling goals.
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Investing in California’s recycling and reuse systems: Producer funding will support infrastructure, programs and other activities needed to strengthen recycling and reuse and advance implementation of SB 54.
Next Steps
CalRecycle will now review the final program plan. In accordance with California’s SB 54 regulations, the agency may approve, disapprove or conditionally approve the submission as it determines whether the plan meets state requirements for implementation by Jan. 1, 2027.
CAA will continue coordinating with CalRecycle, producers, local jurisdictions and other interest holders as the plan moves through review and implementation planning continues.