This article explains the public comment solicitation process for reviewing the implementation rules of California's Plastic Reduction Law (SB54), announced by the California Department of Resources Recycling and Recovery on August 22.
Implementation Rule Review Process
The California Department of Resources Recycling and Recovery (CalRecycle) has published the "rules for permanent implementation" to enforce the state law "Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB54)," announcing the fourth public comment period from August 22 to October 7.
Concurrently, the "Environmental Impact Report" for SB54 under the California Environmental Quality Act (CEQA) was published on August 26, with public comments being accepted from August 26 to October 10. This environmental impact report provides the necessary environmental assessment for achieving SB54's goals and offers opportunities for public participation and stakeholder consultation.
SB54 Specific Requirements
SB54, enacted on June 30, 2022, imposes three obligations on producers:
Improving Recyclability: Requires 100% of single-use packaging materials and single-use plastic food containers sold in the state to be recyclable or compostable products.
Achieving Recycling Rates: Sets a target to recycle 65% of single-use plastic packaging materials and single-use food containers used in the state.
Realizing Reduction Targets: Mandates a 25% reduction in the sale and distribution of single-use plastic packaging materials and single-use food containers compared to 2023 levels.
Background of Major Rule Revisions
CalRecycle initially published implementation rules on April 8, 2024, with plans for enforcement in April 2025 after three rounds of public comments. However, on March 7, 2025, just before implementation, Governor Gavin Newsom (Democrat) ordered a review, citing the significant burden on businesses and consumers.
Improvements in the New Rule Proposal include clearer definitions of terminology, more detailed labeling rules, and modifications that further clarify SB54's content, all based on the previous year's proposal. These comprehensive revisions make corporate compliance more specific and aim to reduce compliance burdens.
Future Schedule
The Department of Resources Recycling plans to hold in-person and online public hearings on October 7, where received public comments will be presented and discussed. Following this final exchange of opinions, the revised implementation rules will be finalized, launching a new regulatory framework for packaging materials in California, the nation's largest economy.
The article evaluates that SB54's implementation could have nationwide impacts on the U.S. packaging and plastics industry, and this rule revision represents an important modification that enhances the industry's ability to comply.