SB 54 Updated Draft Regulations Released

Feedback Needed by May 23

Late last night CalRecycle released updated draft regulations for SB 54. These include the draft text from December of last year with updates based on feedback CalRecycle received from a number of stakeholders including Cal Retailers after the Governor pulled the regulatory process back due to affordability concerns.

Access the Discussion document for the updated draft regulations HERE.


CalRecycle is holding an informal workshop on May 27 as part of the permanent rulemaking process on SB 54. The workshop will be held from 10:00AM PST to 4:00PM PST. The CRA team including CRA President Rachel Michelin and Sarah Pollo Moo will be in attendance.


We need any and all feedback on the updated draft regulatory text by Friday, May 23 including any questions you have so they can be compiled and relayed during the workshop under the CRA brand.


For more information about the workshop including meeting access information and to view the official Public Notice as well as how to submit comments directly to CalRecycle click HERE.


A few items of note on this latest version of the draft regulations:

  • The draft regulatory text has been reduced down from 222 to 175 pages (the document has 185 pages, but that is including text that has been struck out).
  • Registration deadline for producers to register with the PRO was July 1, 2025. Due to the regulatory process being extended, CalRecycle removed a date for the deadline and instead is requiring producers to register within 30 days of the effective regulations.
  • Reporting increments revised from monthly to annual.
  • Reduced frequency of renewals from once per year to once every two years.
  • Article 15 changes for additional producer organizations. Potential 2032 provision to allow CalRecycle to approve multiple PROs was removed. CalRecycle said it is not the right timing to provide requirements for this, so the Department thinks additional specificity is more appropriate in a couple years after program has been implemented.


Snapshot of timeline for updated regulations process (big picture from CalRecycle)

Detailed regulatory timeline from Circular Action Alliance, the Producer Responsibility Organization for SB 54:

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