California’s SB 54 and SB 343: Navigating EPR and Truth in Labeling Compliance
by Justin Given at 13:30 in Circular Economy, Environmental, Packaging

In 2025, California continues to lead the way in packaging regulation, advancing the rollout of its two landmark laws; the Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54) and the Truth in Labelling for Recyclable Materials law (SB 343), as key compliance deadlines draw closer. Together, these measures create a new compliance landscape that combines financial responsibility with marketing accountability. They are not just environmental policies; they will directly shape how packaging is designed, labelled, reported, and ultimately paid for.

SB 54: California's Extended Producer Responsibility Law for Packaging

SB 54, enacted in 2022, shifts the financial responsibility for managing packaging waste from taxpayers to the producers who place it on the Californian market. Its purpose is to incentivise packaging that is reusable, recyclable, or compostable, and to build a sustainable funding model for waste management infrastructure.

The law applies broadly to any producer selling or distributing single-use packaging or plastic foodware in California. "Producer" is defined as the brand owner for packaged goods sold under its name. If there is no brand owner, the obligation falls to the importer or distributor that first sells into California. Manufacturers that supply private-label products may also be responsible if they own the brand or act as the first seller.

Producers must join a state-approved PRO, which will manage collection, recycling, fee structures, and compliance oversight. California has already approved Circular Action Alliance as the PRO under SB 54. Producers will pay fees into the PRO, which will fund recycling system improvements, infrastructure development, and litter reduction programmes.

By 2032, SB 54 mandates a 25% reduction in single-use plastic packaging and requires that 65% of all single-use packaging be recycled. The first producer reports are due on 15 November 2025, covering 2024 sales and packaging data, so early preparation is essential.

Rulemaking

On 7 March 2025, Governor Gavin Newsom directed CalRecycle to restart the rulemaking process for SB 54. This decision followed concerns that the initial draft regulations would impose excessive costs on businesses and consumers. In response, CalRecycle released a revised draft of the regulations, aiming to improve operational readiness and clarify obligations.

The department is currently reviewing feedback. Once finalized, CalRecycle will submit the updated regulations to the Office of Administrative Law (OAL) to initiate the formal rulemaking process. Despite these delays, statutory deadlines and targets set in SB 54 remain in effect, and producers should prepare for upcoming compliance requirements.

SB 343: Truth in Labelling for Recyclable Materials

While SB 54 focuses on cost and producer responsibility, SB 343 zeroes in on the accuracy of recyclability claims. Introduced in 2021, SB 343 tackles greenwashing by redefining what 'recyclable' means in the Californian market. Under this law, the chasing arrows symbol or the word 'recyclable' can only be used if the packaging meets strict, in-state criteria for collection, sorting, and reprocessing.

To qualify, products must be accepted for collection by recycling programmes serving at least 60% of Californians, sorted into defined streams at large processing facilities that also serve at least 60% of statewide programmes, and sent to reclaimers for processing in line with the Basel Convention. They must also meet specific composition and design standards. Alternatively, packaging may qualify if it meets certain recycling rate thresholds, participates in approved non-curbside collection programmes, or complies with other applicable laws governing recyclability or disposal.

For producers, this law goes beyond a simple label review, requiring a full assessment to ensure packaging functions effectively within real-world recycling systems. Compliance deadlines include meeting recyclability standards by 1 October 2026.

How SB 54 and SB 343 Work Together

SB 54 and SB 343 create a linked compliance environment. Packaging that fails to meet SB 343's recyclability definition is likely to attract higher EPR fees under SB 54, while accurate labelling under SB 343 can protect a company from reputational risk and legal liability. Together, these laws push producers towards design changes that achieve both cost efficiency and environmental performance.

If you have any questions about the packaging laws in California, please contact one of our experienced consultants today.

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