Industry Coalition Calls for Immediate Pause on California SB 54 Packaging Mandates

by | Sep 9, 2026 | California Cosmetic Regulations, Cosmetics, U.S. Regulatory, U.S. State Updates

A major coalition of more than 60 national and California-based trade associations are urging the California Legislature to enact an immediate pause on the implementation of Senate Bill 54 (SB 54).     

​SB 54, California’s landmark extended producer responsibility (EPR) and plastic pollution prevention law is facing growing pushback from industry stakeholders as new economic analyses and operational assessments reveal critical flaws in the program’s current framework.

​What Triggered the Push for a Pause?

  • ​Independent assessments based on CalRecycle’s July 2025 Standardized Regulatory Impact Assessment (SRIA) and a February 2026 third-party Needs Assessment project total 5-year compliance costs to reach $78 billion- roughly 3.5 times higher than initial projections.
  • ​Industry faces $2 billion in fees during the first year alone, with initial invoices rolling out and larger fees scheduled for January. Over five years, direct program fees are projected to climb to $17.2 billion (rising from $2B in Year 1 to $5B in Year 5).

The designated Producer Responsibility Organization (PRO), Circular Action Alliance (CAA), has formally indicated that it cannot meet SB 54’s statutory targets as currently written in its Program Plan, raising concerns that massive fees will be collected without achieving the intended recycling outcomes.

​Key Takeaways for Businesses and Regulated Producers:

  • ​The coalition is not advocating for the elimination of SB 54, but rather a temporary legislative freeze. Because the targets and compliance timelines are hardcoded into statute, only the California Legislature can adjust the framework.
  • ​Objective for 2027–2028: The requested pause aims to halt impending fee hikes while lawmakers and industry collaborate during the 2027–2028 legislative session to restructure the program into a workable, cost-effective model.

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If you have any questions regarding how this update may affect your business, do reach out to us today.