Recap of last SB 54 informal rulemaking session

February 1, 2024

CalRecycle held a questions and answers session on the draft regulatory text for the implementation of SB 54 (Allen, Chapter 75, Statutes of 2022). The questions and answers session was the last forum of the informal rulemaking process and covered the following topics:

  • Part I: Overview of SB 54 (Allen, Ch. 75, Stat. 2022). An overview of SB 54, including program goals and objectives, producer requirements, statutory timelines and responsibilities of the Department.
  • Part II: Overview of the Rulemaking Process in California. An overview of the rule making process in California and where CalRecycle is at with this process for SB 54.
  • Part III: Overview of the Draft Regulations. An article-by-article walkthrough on Draft Regulatory Text, including Chapter 11.1 Plastic Pollution Prevention and Packaging Producer Responsibility (with 15 articles) and Chapter 11.5 Environmental Marketing and Labeling (with one article).


The CRA team attended, you can read the recap HERE. Questions and comments on the draft SB 54 regulatory text can be sent to CalRecycle anytime, however, if you wish to have your comments and questions recorded and reviewed by the Office of Administrative Law (OAL), submission must be made during the 45 day comment period, which is expected to start in a couple months with the first hearing in the Spring (according to CalRecycle). If you would like the CRA team to submit on questions or comments on your company's behalf, please email sarah@calretailers.com. Today's presentation slides will be posted by CalRecycle in a few days, which the CRA team will share with our members once they are up.


As a reminder, CRA's President and CEO Rachel Michelin is serving on the inaugural Plastic Pollution Prevention and Packaging Producer Responsibility (SB 54) Advisory Board, which will have its first meeting tomorrow, Friday, February 2. The meeting is open to the public. For information on that meeting including an agenda and instructions on how to participate click HERE.


Michelin was named to the Advisory Board last year and will be serving as an important voice for the retail industry and larger business community during the SB 54 rulemaking process. Read the advisory board announcement here. View the entire list of board members here.

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