On October 13, 2026, Circular Action Alliance submitted its final SB 54 program plan to CalRecycle outlining producer fees, source-reduction measures, recycling investments, and compliance options. Meanwhile, plaintiffs, including the Personal Care Products Council (PCPC), are seeking to expand an existing lawsuit to challenge provisions related to recyclability, packaging design, producer obligations, and consumer fee disclosures.

Although litigation could affect certain provisions, it does not currently pause SB 54 implementation. Companies should continue preparing for potential packaging compliance requirements and associated costs while monitoring regulatory and legal developments. For more such updates, follow us.