At its surface, the new-in-2026 SB54 legislation is California's version of EPR: just like with Oregon and Colorado, brands must register with the Circular Action Alliance, report data that accounts for their packaging weights by type, and pay corresponding fees.

However, California’s EPR law goes a step further: brands need to also submit a realistic plan to reduce the volume of plastic in their packaging by 2027. By a lot. And, as we’ve learned in the past, California doesn’t mess around. Large penalties are at stake.

We’re not trying to be alarmist, but brands really do need to start planning now. You’ve got one shot to submit a plastic-reduction plan you can actually implement. The deadline is August 1, 2026.

You’ve got some work to do. EcoEnclose can help.

SB 54 sets mandatory, absolute plastic 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

You read that right. The benchmark is your 2023 baseline. So if your business used 10 tons of plastic in packaging in 2023 and you’ve grown by 25% since then, you still need a plan to reduce to 9 tons by 2027 (and 7.5 tons in 2032).

On top of that, California has proposed an additional requirement of achieving 25% post-consumer recycled (PCR) content in your 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 these requirements.

Okay. Have your moment of panic, and now let’s get to work.

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-based mailer eliminates 100% of the plastic in those mailers by substituting paper for it
• Removing a shrink band from a retail product does the same, by eliminating that non-critical plastic
• Downgauging a poly bag from 1.5 mil to 1.25 mil thickness “lightweights” plastic weight by roughly 15 to 20% per unit

In Oregon, paper incurs fees of around $0.03 per pound, while HDPE/LDPE flexible film incurs $0.76 per pound.

Start with these 5 steps.

1. Submit or confirm your 2023 baseline packaging weight 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.

4. Start building a plastic reduction roadmap to 2027. That’s closer than it sounds, especially when you’re talking about real transitions. The brands that begin now can phase transitions in gradually. The brands that wait face rushed decisions and higher costs.

5. Budget for fees and transitions. This has to be part of your 2027 corporate P&L. 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 tough decisions, supplier negotiations, trial runs, and internal approvals.

EcoEnclose can help. Let's hop on the phone.

We've also 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.