Packtally guide
California SB 54 packaging EPR: a guide for Shopify brands
California's SB 54 packaging law for online brands: who the producer is, registration, reports, the small producer exemption and the 2032 rule.
Short answer: SB 54 is California's packaging EPR law. Its final regulations took effect May 1, 2026. Brands that sell packaged products into California, including online, register through Circular Action Alliance (CAA) or directly with CalRecycle, report their packaging and pay fees. Brands with under $1 million in California sales can apply to be exempt from most of it.
Who the producer is
For branded products, the producer is usually the brand owner: the company whose name is on the product. Unlike most other states, California also puts the shipping box on the brand owner, even when a 3PL packs the order.
What producers had to do in 2026
| Requirement | Date |
|---|---|
| Final regulations take effect | May 1, 2026 |
| Register with CAA, register as an independent producer, or apply for the small producer exemption | June 1, 2026 |
| Annual supply report (2025 data) and 2023 baseline report | June 1, 2026 (May 31 fell on a Sunday) |
| Annual source reduction report | May 31, 2026 |
| Individual source reduction plans | Expected by August 1, 2026 |
Reports on 2026 data are expected on the same yearly schedule in 2027.
The small producer exemption
Producers with under $1 million in gross sales in California in the most recent calendar year can apply to be exempt from most reporting and fee requirements. It isn't automatic: you register in CalRecycle's system and apply with proof of sales. Step-by-step in How to claim California's small producer exemption.
The 2032 rule applies to everyone
By 2032, packaging sold into California has to be recyclable or eligible to be labeled compostable under California law. The small producer exemption doesn't cover this requirement, so even exempt brands should plan their packaging with it in mind.
Penalties
California's law allows administrative penalties of up to $50,000 a day per violation, or $25,000 a day for producers that meet the small producer criteria.
Our reading of CalRecycle's guidance and published legal summaries as of October 2026, for orientation only and not legal advice.