California’s approach to packaging waste is entering a new phase, with implications for companies that manufacture, import and sell consumer products in the state. Businesses that once treated packaging primarily as a matter of design, protection and cost now have additional questions to consider: Which materials are covered by the law? Who is responsible for compliance? And could changes to packaging affect product costs or supply chains?
The central legislation is Senate Bill 54, known as the Plastic Pollution Prevention and Packaging Producer Responsibility Act. Signed into law in 2022, it establishes an extended producer responsibility framework for covered packaging and single-use plastic food service ware.
The permanent regulations took effect on May 1, 2026. In October 2026, California’s Department of Resources Recycling and Recovery, known as CalRecycle, received a producer responsibility plan submitted by Circular Action Alliance. The agency has 75 days to review the plan for compliance. These developments mark important steps in implementation, although businesses should continue monitoring official guidance as the program develops.
For brands, retailers and importers, the issue is no longer simply whether packaging looks appropriate for a product. It is also whether the business understands the materials it uses, its position in the supply chain and the requirements that may apply to its operations.
What Does California’s SB 54 Require?
SB 54 establishes several long-term objectives for covered single-use packaging and plastic food service ware. By 2032, the law aims to reduce covered single-use plastic packaging and food service ware by 25%, recycle 65% of covered single-use plastic packaging and food service ware, and ensure that all covered single-use packaging and plastic food service ware is recyclable or compostable.
These targets are intended to encourage less unnecessary packaging, improve the management of materials after use and support investment in collection and recycling infrastructure.
However, the law should not be interpreted as a blanket requirement that every package must immediately be replaced. Coverage depends on the relevant material categories, the business involved and applicable exemptions or exclusions.
For example, a package may contain several components made from different materials. The main box, a plastic window, an insert and a surface coating may need to be evaluated separately. The fact that the outer packaging is paper-based does not necessarily settle every question about the complete package.
Businesses should therefore distinguish between general environmental preferences and the specific definitions and determinations used under California’s law. The state’s covered material category list and producer guidance provide a more reliable basis for assessing particular materials than broad claims that a package is simply recyclable, sustainable or environmentally friendly.
Who Is Responsible for Packaging Compliance?
Extended producer responsibility, or EPR, is designed to make businesses more accountable for the waste associated with products they introduce to the market.
Under SB 54, the responsible producer is determined by the legal definitions and circumstances of the relevant business relationship. Depending on the situation, this may involve a brand owner, importer, manufacturer or another entity identified by the rules.
This distinction matters for companies that outsource production. A business might commission packaging from an external manufacturer, but that commercial arrangement does not automatically transfer all regulatory obligations to the supplier.
Consider a company that sells skincare products in California. It may purchase empty boxes from an overseas packaging manufacturer, fill them with its own products and sell the finished goods under its brand. The manufacturer controls the production of the boxes, while the brand controls the finished product and its route to market. The respective responsibilities need to be assessed under the applicable law rather than assumed from the manufacturing contract alone.
Companies should establish whether they must participate in the approved producer responsibility organization, comply independently or qualify for an applicable exemption. They should also determine which reporting and fee obligations apply to their specific circumstances.
CalRecycle publishes guidance to help businesses identify covered materials and determine whether they qualify as producers. Because the rules contain specific definitions and exclusions, companies should consult official guidance or qualified legal advisers before making compliance decisions.
Why Packaging Specifications Matter More Than Ever
A useful first step for businesses is to understand exactly what their packaging contains.
Product packaging is often more complex than it appears. A box may combine paperboard with a plastic window, a fitted insert, a laminated surface, a coating or other components. Each element can influence the package’s functional properties and its assessment under relevant requirements.
Businesses should create an inventory of packaging formats across their product lines. For each format, the inventory can record the materials used, the number of components, the supplier, the product category and any existing documentation about recyclability or material composition.
This information can help purchasing teams identify where additional information is needed and which products may warrant further review.
Companies evaluating custom boxes for their products should consider material specifications alongside dimensions, printing, structural design, finishes, product protection and cost. A design that works well for one product may not be suitable for another, especially when different materials or components are involved.
Supplier communication is important here. Manufacturers should be able to explain the construction of the packaging they produce and provide accurate information about its materials. Businesses can then use that information as part of their own assessment of regulatory obligations.
It is equally important to distinguish between a material specification and a compliance guarantee. A supplier’s statement that a box is made from paperboard does not necessarily establish that every component of the complete package satisfies a particular legal requirement.
Does Switching From Plastic to Paper Solve the Problem?
Material substitution is one possible response to packaging concerns, but it should not be treated as a universal solution.
Paper-based packaging can offer structural strength, printability and a range of design options. Plastic components may be used where transparency, moisture resistance or a particular protective function is needed. Other formats may combine several materials to meet product-specific requirements.
The appropriate choice depends on the product, the package’s construction, its intended use and the relevant regulatory criteria.
A business considering a change should assess the entire package rather than focusing exclusively on its largest component. For instance, replacing a plastic outer shell with a paperboard structure may still leave questions about a window, insert, coating or closure.
Companies should also consider how a change affects product protection and transport. Packaging must still perform its primary function of keeping products safe during handling, storage and delivery. A material change that increases breakage or product damage could create other costs and waste.
The practical objective is to identify a packaging design that meets the product’s requirements while supporting the business’s material, operational and regulatory priorities. That decision may involve a redesign, a change in components or simply better documentation of the existing package.
What Should Businesses Ask Their Packaging Suppliers?
The implementation of SB 54 gives companies a reason to make supplier discussions more specific. Rather than asking only for a unit price and production schedule, purchasing teams can request information that helps them understand the packaging being supplied.
Several questions are worth considering:
- What materials are used in the main package and in each separate component?
- Are any plastic windows, inserts, coatings or mixed-material elements included?
- Can the supplier provide material specifications and supporting documentation?
- Are alternative structures available that preserve the required protection and presentation?
- Would a proposed design change affect manufacturing lead times, minimum order quantities or unit costs?
- Can the supplier maintain consistent specifications across repeat orders?
These questions can help businesses make more informed procurement decisions. They can also reveal potential trade-offs early, before artwork, tooling or production has progressed too far.
Companies should be careful not to ask manufacturers to make legal determinations beyond their expertise. Suppliers can provide information about materials and manufacturing processes, but the business placing products on the market may need separate regulatory or legal advice.
Clear documentation is especially useful when a company works with several suppliers or sells multiple product lines. Consistent records make it easier to compare packaging options, investigate changes and provide information when required.
How Packaging Changes Can Affect Costs and Operations
Packaging redesign is not only a materials decision. It can influence product costs, storage, manufacturing efficiency and shipping arrangements.
A different box structure may require new tooling or adjustments to production equipment. A change in insert design can affect assembly time. Different dimensions may alter how many packages fit into a shipping carton or how efficiently finished goods can be stored.
For products sold at scale, even small changes in the dimensions or materials of a package can affect the economics of a production run.
Companies should therefore consider total cost rather than comparing materials on unit price alone. Relevant factors can include design and sampling, tooling, manufacturing, assembly, transportation, storage and the risk of product damage.
The timing of a redesign matters as well. Businesses preparing a product launch may need to coordinate packaging changes with artwork approval, product testing, production capacity and delivery dates. Starting the review early provides more flexibility to evaluate alternatives without disrupting the launch schedule.
Where a business has multiple products, it may be more practical to prioritize packaging formats that require the closest review rather than attempt to change every package simultaneously.
Why Documentation and Traceability Matter
A packaging inventory is most useful when the information remains accurate over time.
Materials may change between production runs, suppliers may introduce new components, and packaging designs may be updated to accommodate a new product or production method. If the documentation is not updated accordingly, a company may be relying on information that no longer reflects the package it purchases.
Businesses can reduce this risk by maintaining records of approved specifications, supplier declarations, material changes and the date each version entered production.
A formal change-approval process can also help. Before a supplier substitutes a component or alters a material, the purchasing team should understand whether the change affects product performance, documentation or the company’s compliance assessment.
This is not unique to California’s law. Accurate packaging records can support quality control, cost management and supplier accountability across a company’s operations.
For businesses that source packaging internationally, clear specifications are especially important because the buyer and manufacturer may operate in different regulatory environments and communicate across multiple teams.
What Small Businesses Should Consider
Smaller companies may have fewer resources to devote to regulatory reviews, but they can still take practical steps to understand their position.
The first is to determine whether the business and its packaging fall within the scope of SB 54. Certain exemptions and exclusions may apply, including provisions for qualifying small producers, but eligibility depends on the law’s specific criteria and application requirements.
Businesses should not assume that a small order quantity alone means an exemption applies. They should check the relevant definitions and procedures and retain records of the assessment.
The second step is to review existing supplier information. A company that already has accurate material specifications may be better prepared to identify which questions need further attention.
Finally, businesses should avoid making costly packaging changes based solely on general headlines. Understanding the applicable requirements first can help them distinguish necessary changes from optional improvements.
A structured review does not have to begin with a complete redesign. It can start with a list of products, a record of packaging components and a discussion with suppliers about available documentation.
Choosing the Right Box Structure
Regulatory considerations are only one part of a packaging decision. Businesses must also select a structure that suits the product’s weight, fragility, distribution method and price point.
Folding cartons, corrugated boxes and rigid boxes serve different purposes. A folding carton may suit lightweight retail products, while corrugated packaging can provide protection for shipping. Rigid boxes are often selected for premium products that require a sturdy structure and a more substantial presentation.
Companies sourcing custom rigid boxes should evaluate the materials, inserts, finishes and construction early in the design process. The choice of structure can affect product protection, shipping efficiency, manufacturing costs and the materials that need to be documented.
No single box type is appropriate for every product. The most effective approach is to compare practical requirements, obtain clear specifications and ensure that the selected packaging supports both the product and the company’s operational needs.
What Happens Next?
The implementation of SB 54 involves more than the adoption of regulations. It also requires the administration of the producer responsibility program, guidance for businesses, decisions about covered materials and continuing work on the systems used to manage packaging waste.
CalRecycle’s review of the producer responsibility plan submitted in October 2026 is one part of that process. Businesses should monitor official updates for changes and clarifications that affect their products, reporting responsibilities or material classifications.
The state also maintains information about exemptions, exclusions and covered material categories. These resources are important because the details can determine whether a particular package or business is subject to specific obligations.
Companies should base decisions on current official guidance rather than assume that a general summary covers every circumstance.
For businesses selling into California, the most practical approach is to understand their responsibilities, maintain reliable packaging records and discuss material specifications with suppliers early in the product development process.
California’s packaging rules highlight how procurement, product design and regulatory planning increasingly overlap. Businesses that understand their packaging and keep their documentation current will be better positioned to respond as the program develops, while making informed decisions about cost, product protection and materials.
