California packaging EPR regulations face further delay as draft rules withdrawn for revision

Draft regulations intended to implement California’s extended producer responsibility (EPR) programme for packaging have been withdrawn from formal review, signalling another delay in the state’s regulatory timeline ahead of its planned rollout in 2027.

The California Department of Resources Recycling and Recovery (CalRecycle) withdrew the proposed rule language for the state’s Plastic Pollution Prevention and Packaging Producer Responsibility Act (commonly known as SB 54) from consideration by the Office of Administrative Law on 9 January 2026. According to agency statements, the move is intended to allow revisions that improve clarity and support effective implementation of the law, with a particular focus on provisions relating to food and agricultural packaging.

CalRecycle has indicated that it will open an additional 15-day public comment period once updated draft regulations are available, although a start date for this comment window has not yet been confirmed. Despite this step back in the rulemaking process, statutory deadlines established under SB 54 remain unchanged, and the programme’s implementation date of January 2027 continues to stand.

SB 54, enacted in 2022, requires producers of single-use packaging and plastic food service ware sold or distributed in California to help fund and manage the end-of-life processing of those materials. Among its longer-term requirements, the law aims to ensure that covered packaging is recyclable or compostable, supports significant source reduction, and increases recycling rates for specified material types by 2032.

This latest adjustment follows a series of revisions and resets in the regulatory process over the past year, as stakeholders from industry, government and advocacy groups have engaged in discussions on how best to translate the broad legislative goals of SB 54 into practicable regulatory language.

Producers and compliance organisations are continuing preparations for the eventual implementation of the EPR programme, including reporting and planning activities required in advance of the 2027 start date. The renewed public comment period will provide another opportunity for feedback from industry groups and other interested parties ahead of finalisation.