At its surface, SB 54 is just California's version of Extended Producer Responsibility: register with Circular Action Alliance, report your packaging data, pay fees.

It’s accurate, but only covers half of what California requires.

California doesn't just require you to account for your plastic; its legislation actually requires you to use less of it. And that distinction matters enormously for how you plan.

Reporting and paying fees are compliance exercises. Reducing plastic is a design and operations challenge that pushes brands to solution-engineer, run pilots and tests, bring together departments from marketing to warehousing to implement changes, and manage against lead times, as we all know, packaging transitions don’t happen overnight.

SB 54 sets mandatory, absolute reduction targets measured against your 2023 packaging baseline:

• 10% reduction in plastic packaging weight by January 1, 2027

• 25% reduction by January 1, 2032

• 65% plastic packaging recycling rate by 2032

If you are liable for Extended Producer Responsibility in California, you have to meet these reduction targets. And your growth rate doesn’t change the mandate. If you’re growing year over year, you still need to achieve an absolute reduction in your plastic.

On top of that, California is expected to require approximately 25% post-consumer recycled (PCR) content in plastic packaging by 2028, increasing to 30% by 2032. Any PCR content requirements that are implemented would not count toward your source reduction target. You’d have to hit both independently.

If you sell into California and gross more than $1 million in the state, assume you are liable for extended producer responsibility, and therefore, SB 54, unless you can explicitly demonstrate otherwise.

CalRecycle has defined five explicit pathways to reduce your plastic usage:

• Elimination
• Material Substitution,
• Lightweighting
• Moving to Reuse/Refill Models
• Bulking/Concentrating Packaging

For example:

• Switching a poly mailer to a paper-padded mailer eliminates 100% of the plastic component by substituting paper for it

• Removing a shrink band from a retail product does the same, by eliminating the solution

• Downgauging a poly bag from 1.5 mil to 1.25 mil reduces plastic weight by roughly 15 to 20% per unit, by lightweighing the packaging

One benefit is that material choices that support plastic reduction also have a direct and significant effect on your EPR fees.

Oregon's published 2025 fee schedule, which is the most concrete data we have, shows kraft paper running around $0.03 per pound while HDPE/LDPE flexible film runs $0.76 per pound.

Flexible plastic packaging designed for source reduction often maps directly to lower EPR costs as well.

Start with these 5 steps.

1. Submit or confirm your 2023 baseline data by May 31st, 2026. This is the number everything else is measured against, and the window to submit without penalty is still open.

2. Audit which SKUs are driving your plastic weight. You cannot build a reduction plan without knowing where you stand.

3. Calculate the gap between your current plastic footprint and the 10% reduction required by 2027. That deadline is closer than it feels.

4. Start building a reduction roadmap. The brands that begin now can phase transitions in gradually. The brands that wait face rushed decisions and higher costs.

5. Budget for fees. Plan for a 15-40% uplift in packaging spend as EPR programs mature across California, Colorado, and Oregon.

The 2027 deadline is just around the corner, and does not give you much runway for packaging transitions that require sourcing decisions, supplier conversations, testing, and internal approvals.

We've put together a practical toolkit to help you work through each of these steps, from auditing your plastic footprint to building a reduction roadmap to understanding how your packaging choices translate into EPR fee exposure.

EcoEnclose is a sustainable packaging provider helping brands optimize packaging choices to align with EPR laws—reducing fees, minimizing plastic use, and building smarter long-term strategies.