California’s landmark SB 54 (Plastic Pollution Prevention and Packaging Producer Responsibility Act), signed in June 2022, mandates that by 2032 all single-use packaging and plastic food-service ware be recyclable or compostable, with an additional mandate that the industry demonstrate a 30% recycling rate for all single-use packaging by January 2028. The program is funded by producers of the single use packaging with producers contributing $5 billion over ten years, i.e. ~$500 million per year from 2027 to 2037.
By March 08, 2025, CalRecycle was expected to finalize its implementing regulations—but Governor Newsom rejected the initial draft over business cost concerns. In response, CalRecycle released a revised draft in mid-May 2025, incorporating key stakeholder input: simplified fee structures (eco-modulation fees), extended exemption periods (minimum two years, up to five), annual rather than monthly reporting, and revised thresholds for de minimis components.
A public workshop on the updated draft was held May 27, with comments due by June 03. CalRecycle has been reviewing these comments and aims to initiate formal rulemaking shortly. Meanwhile, key compliance deadlines remain in place: companies should expect to report 2023 packaging/sales data by November 15, 2025, and begin paying fees by January 01, 2027.
Additional action: California has effectively banned expanded polystyrene (EPS) food-service ware as of January 01, 2025, since EPS producers failed to meet a 25% recycling rate threshold.
Oregon’s Recycling Modernization Act (Senate Bill 582) became effective January 01, 2022, but the operational phase—including the packaging EPR program—officially launched on July 01, 2025.
Circular Action Alliance (CAA) was approved as the state’s sole PRO on February 21, 2025, and is responsible for administering registration, data reporting, fee schedules, and funding mechanisms. Initial production data from over 1,700 producers was reported by March 31, 2025, with a registration deadline extended to April 30, 2025.
Fee invoices were issued to Producers in May and June, and fee payments began July 01, 2025, covering 2024 material volumes. Pre-program spending is estimated at $188 million in 2025, ramping up to $254 million in 2026 and $289.5 million in 2027. Sixteen “priority A” communities received an initial $17.5 million in early investments.
Oregon producers who fail to register or file reports risk enforcement by DEQ, including civil penalties up to $25,000 per day. Products registered providers now help CAA set equitable per-ton fees: more participants means lower per-ton costs.
These regulatory shifts underscore the need for transport and cold chain packaging firms to review operations, prepare financial forecasts for fees, and collaborate with CAA. Monitoring upcoming rulemakings in California—or potential legislative tweaks—is essential in aligning design, supply, and compliance planning.
At EFP, sustainability is a critical goal. We are working with state regulators, industry associations and our customers to stay on top of the latest development in EPR legislation and regulation. EFP is taking a leadership position in the EPS industry as we work to increase EPS recycling rates across the country, and work with our customers to quickly adopt the use of EPS with 30% to 50% recycled content.
Written by Joe Grzyb, Director of Sustainability.
Joe Grzyb (pronounced “Gribb”) has over 25 years of experience in leading, managing, and growing high-tech companies primarily in the temperature-controlled packaging industry. Joe was a Co-Founder of NatureKool® and he now joins EFP as our first-ever Director of Sustainability. Before joining EFP, Joe held positions such as Founder of Aspen Technologies, CEO of Phase Change Energy Solutions, and leadership roles at AmeriTech Exports, ITT Defense and the US Air Force.
