California’s Crackdown on Non-Recyclable Plastics: SB 54 and the Future of Waste
California is setting a powerful example for the world by holding producers responsible and forcing a shift toward truly recyclable packaging.
California has long been at the forefront of environmental policy in the United States. With the passage of SB 54—the Plastic Pollution Prevention and Packaging Producer Responsibility Act—the state is now tackling the challenge of non-recyclable plastics head-on. The landmark legislation reimagines who is responsible for the rising tide of plastic waste and sets bold new standards for what materials can enter the state’s recycling stream.
Table of Contents
- Introduction: The Scale of Plastic Pollution
- What Is SB 54? A Turning Point in Packaging Policy
- Core Targets: Reduction, Recycling, and Responsibility
- Who Is Impacted by SB 54?
- What Materials Are Covered?
- Timeline: How and When the Changes Roll Out
- Shifting the Burden: From Taxpayers to Producers
- The Role of the Producer Responsibility Organization
- Challenges and Pushback: Cost, Clarity, and Compliance
- The Special Case of Polystyrene Foam
- Expected Impact: On California and Beyond
- Frequently Asked Questions (FAQs)
Introduction: The Scale of Plastic Pollution
Plastic pollution is a global crisis. Much of what is labeled as “recyclable” ends up in landfills, exported overseas, or polluting waterways and beaches. In the U.S., only a small proportion of plastic waste—less than 10%—is ever recycled effectively. California, as one of the world’s largest economies, both contributes to and suffers from this waste stream, making action on plastics a necessity for environmental health and public trust in recycling systems.
What Is SB 54? A Turning Point in Packaging Policy
Passed in June 2022, California’s Senate Bill 54 (SB 54), the Plastic Pollution Prevention and Packaging Producer Responsibility Act, redefines how plastic and packaging waste should be managed. Rather than leaving cities and taxpayers to fund the recycling system, SB 54 shifts responsibility to the companies that manufacture packaging and single-use plastic products destined for California’s market. The Act reflects growing calls to bring “extended producer responsibility” (EPR) into the plastic arena, holding those who profit from packaging accountable for its lifecycle.
Core Targets: Reduction, Recycling, and Responsibility
SB 54 sets out measurable, ambitious targets aimed at:
- Reducing total single-use plastic packaging by 25% by 2032.
- Achieving a 65% recycling rate for single-use plastic packaging and food service ware by 2032.
- Ensuring 100% of single-use packaging and food service ware are recyclable or compostable by 2032.
- Setting interim goals, such as a 10% reduction by 2027 and 20% by 2030.
These requirements apply specifically to plastics, while the requirement for all single-use packaging to be recyclable or compostable covers a wider range of materials, including glass, metal, paper, and renewable organics.
Who Is Impacted by SB 54?
While the law covers all producers of single-use packaging—from large consumer goods companies to food vendors—the primary responsibility rests with brand owners. In many cases, even if a company does not directly manufacture plastics, they will need to ensure compliance for any covered material they introduce into the California marketplace. Retailers and distributors may also bear compliance duties if they act as the producer or last point of sale.
What Materials Are Covered?
SB 54’s reach is broad. It covers:
- All single-use plastic packaging: bottles, containers, trays, wrappers, and more
- Single-use food service ware: plastic cutlery, plates, bowls, and cups
- Other packaging materials like glass, aluminum, paper, wood, and fiber
What others are reading
“Covered materials” are defined by the California Department of Resources Recycling and Recovery (CalRecycle), which updates the Covered Material Category (CMC) list periodically. If an item cannot realistically, consistently, and economically be recycled, it is likely to be phased out.
Timeline: How and When the Changes Roll Out
| Year | Key Requirement |
|---|---|
| 2022 | SB 54 signed into law, initiating rulemaking and implementation planning |
| 2023 | Initial Covered Material Category list released; stakeholder engagement intensifies |
| 2025 | Draft regulations published; rulemaking and public comment periods (ongoing as of late 2025) |
| 2027 | Producers must join a Producer Responsibility Organization (PRO) and achieve a 10% reduction in plastics |
| 2030 | 20% reduction in single-use plastic packaging required |
| 2032 | Full targets: 25% reduction, 65% recycling rate, and 100% recyclability/compostability for covered materials |
Deadlines for regulatory guidance have been delayed due to stakeholder opposition and concerns about cost, but statutory targets remain legally binding, and both the state and industry are working to maintain momentum.
Shifting the Burden: From Taxpayers to Producers
Historically, Californians have paid for recycling infrastructure through municipal bills and taxes, despite most costs being incurred by producers’ choice of materials. Under SB 54:
- Producers fund the full cost of collecting, sorting, recycling, and disposing of packaging waste.
- Fees support the development of recycling systems, reduction strategies, and public education.
- Government agencies like CalRecycle oversee enforcement and compliance.
This approach, called extended producer responsibility (EPR), is gaining favor worldwide, reflecting a principle that those who profit from the sale of disposable goods should also carry the burden of managing their environmental impact.
The Role of the Producer Responsibility Organization
To coordinate these new responsibilities, a Producer Responsibility Organization (PRO) is designated by the state. In California, the Circular Action Alliance has been chosen for this role. The PRO’s duties include:
- Collecting fees from all covered producers
- Managing funds to support recycling programs and innovations
- Reporting progress and ensuring both reduction and recycling targets are met
- Working with government, waste haulers, recyclers, and affected industries for continuous improvement
By pooling resources, the PRO aims to create economies of scale and promote industry-wide innovation and compliance.
Challenges and Pushback: Cost, Clarity, and Compliance
Despite its environmental ambitions, SB 54 faces significant hurdles:
- Cost concerns: The initial regulatory package was estimated to cost $36 billion to implement, with potential increases of $300 annually per household, prompting Governor Newsom to demand revisions. Businesses worry about bearing new costs; environmental advocates warn against delays.
- Complex supply chains: Producers must track, report, and reformulate packaging for a sprawling array of products, suppliers, and materials.
- Determining recyclability: CalRecycle’s evolving CMC list means some materials (currently labeled as “recyclable”) may later be flagged for phase-out if recycling rates fall short.
- Implementation delays: Draft rules were sent back by the Governor in March 2025 for revision, and final regulations are still pending, with ongoing public workshops and comment periods.
Getting the regulations right demands balancing ambition with feasibility—and working with a complex mix of stakeholders, from large corporations to small businesses and environmental justice advocates.
The Special Case of Polystyrene Foam
One of the most contentious forms of packaging is polystyrene foam (often known by the brand name Styrofoam). SB 54 prohibits the sale of products like foam cups or trays unless producers can prove a 25% recycling rate—a threshold that has not been met, since the U.S. recycling rate for polystyrene hovers around 1%.
Despite these bans, enforcement has lagged, with environmental groups alleging insufficient action by CalRecycle. Advocacy groups argue that until rigid accountability measures are in place, non-recyclable polystyrene will continue to pollute land and water. Calls for stricter enforcement are mounting as California seeks to lead not just in policy, but in practice.
Expected Impact: On California and Beyond
California’s new approach represents a major step towards closed-loop recycling and could have ripple effects nationwide:
- Large companies may redesign packaging for national distribution, driving up U.S. and global standards.
- Material bans and strict recycling requirements will reduce waste exports to countries lacking adequate processing infrastructure.
- Producers will be incentivized to use less material, adopt reusable systems, or find compostable alternatives.
- Consumers may see fewer “wish-cycled” items (items placed in the recycling bin with the hope they’ll be recycled) in their blue bins. What is accepted in recycling streams will truly be recycled.
By moving from voluntary industry pledges to legally binding rules, California provides a playbook for other states and countries aiming to stem the tide of plastic pollution and restore confidence in recycling.
Frequently Asked Questions (FAQs)
Q: Who pays for recycling under SB 54?
A: Under SB 54, the cost burden is shifted from taxpayers and local governments to producers of covered materials. These businesses will fund all required collection, sorting, and recycling or disposal programs through fees paid to the Producer Responsibility Organization.
Q: Which plastics are being phased out in California?
A: Any single-use plastics and food service ware that cannot be economically and consistently recycled at scale will be required to be phased out by 2032. These include certain multilayer wraps, black plastics, and polystyrene foam products, among others.
Q: What must producers do by 2027?
A: By January 1, 2027, producers must join a Producer Responsibility Organization and reduce single-use plastic packaging and single-use plastic foodware by 10% statewide, tracking and reporting their progress annually.
Q: Are compostable plastics included?
A: Yes. By 2032, all single-use packaging and food service items must be either recyclable or certified compostable, as determined by CalRecycle’s official lists and definitions.
Q: How will compliance be enforced?
A: CalRecycle is tasked with enforcing compliance, reviewing annual reports, and imposing fines or bans on products and producers that fail to meet the recycling and reduction targets. However, environmental groups argue that enforcement remains a concern, particularly for problematic materials like polystyrene foam.
Additional Resources for Further Reading
- California Department of Resources Recycling and Recovery (CalRecycle): Information on SB 54 and ongoing rulemaking
- Circular Action Alliance: The state’s Producer Responsibility Organization
- Reports and presentations on material characterization and packaging reforms
- Advocacy groups like Beyond Plastics for up-to-date information on enforcement and compliance campaigns
California’s SB 54 isn’t just an incremental reform—it’s a blueprint for holding producers of waste accountable, transforming the recycling paradigm, and cleaning up the world’s supply chains. The battle over plastics is far from over, but with these new rules, California is redrawing the lines.
References
- https://www.bdlaw.com/publications/calrecycle-reissues-draft-sb-54-regulations-targeting-californias-plastic-packaging-epr-program/
- https://resource-recycling.com/recycling/2025/05/15/first-person-perspective-key-developments-in-californias-plastic-laws/
- https://calrecycle.ca.gov/packaging/packaging-epr/
- https://www.beyondplastics.org/press-releases/ca-ban-enforcement-6-3-25
- https://calrecycle.ca.gov/plastics/carryoutbags/
- https://california.surfrider.org/california-plastic-pollution-reduction-laws
- https://sustainablepackaging.org/2025/09/23/packaging-policy-news/
- https://www.latimes.com/environment/story/2025-06-19/is-california-winning-its-war-on-plastic-bags
- https://circularactionalliance.org/california
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