California’s SB 54 packaging EPR program is moving toward its first major compliance cycle. Producers must submit:

• Baseline Report using CY 2023 data (late submissions are still being accepted)
• Final Baseline Report within 30 days of regulation finalization in 2026 (CY 2023 data): estimated April 2026
• Producer Supply Report using CY 2025 data by May 31, 2026
• Annual Source Reduction Report using CY 2025 data by May 31, 2026
• Individual Source Reduction Plan (date TBD), no later than Aug 1, 2026
• Early Fees in August 2026, based on 2025 packaging data

California is operating under “interim rules,” with final regulations expected in 2026. This makes 2026 a pivotal year for producer compliance, data accuracy, and budgeting.

2026 California EPR Timeline (At a Glance)

Table: California Packaging EPR Reporting & Payment Schedule

California’s early-fee structure is unique: 2026 fees are based on 2025 data (not 2024 like OR/CO).

Who Must Comply (Producer Definitions)

California follows the standard EPR producer hierarchy:

1. Brand Owner
2. Licensee
3. Importer of Record
4. Retailer (as last resort)

Most consumer-facing brands will be directly obligated.

California’s SB54 regulation covers:

• All primary, secondary, tertiary packaging and plastic food-service ware
• Single-use packaging of all materials
• E-commerce packaging
• Some reusable packaging depending on use-case

Check if you are liable in California using our Free tool here.

2026 Reporting Requirements: What You Must Submit

1. Packaging Data

California requires:

• Component-level (and sometimes sub-component-level for plastics) detail
• Plastic resin types + all other material categories
• Weights of each component
• PCR content
• Recyclability attributes under CA’s emerging framework (Note: All individual producers are to have 100% recyclable or compostable packaging by 2032)

You can learn more in this detailed guide for California EPR here. 

2. Source Reduction Report and Plan [Compared to 2023 Baselines]

Source reduction is one of the core pillars of California’s SB54 system, and beginning in 2026 every producer will be required to submit an Individual Source Reduction Plan outlining how they will meaningfully reduce the amount of packaging they introduce into the state. In addition, California requires an Annual Source Reduction Report to track supply data and source reduction activity.

California has defined five approved source reduction pathways, including reuse or refill models, material elimination, material substitution, concentrating or shifting to bulk format, and alternative compliance (use of PCR). Producers will need to quantify 2023 data baselines, set reduction targets aligned with the state’s 2032 goals, and demonstrate credible pathways for implementation. 

CAA has published a reporting workbook and detailed guidance to help producers report in compliance with SB54 requirements.

For a deeper explanation of how source reduction works and what it means for producers, read our blog post on CA Source Reduction.

California’s Early Fee Structure (What It Means for 2026 Budgets)

Extended Producer Responsibility (EPR) fees fund recycling, collection, and infrastructure improvements at a state level. Therefore, California bases its fees on its own circular economy roadmap and existing infrastructure. 

Starting in 2026, producers selling into California must report detailed packaging data and pay annual fees based on their material footprints. California applies a per-kilogram fee rate by material category and adjusts it with eco-modulation (bonuses or penalties for design choices). You can learn more in this detailed step-by-step guide for California EPR here.

California is the only EPR state using 2025 data to generate early fee invoices in 2026. Note that early fees are only “pre-program fees” to start-up the program in California. Producer final fees (beginning 2027) will be higher than the early fees since they would include total program cost and not just start-up cost.

Fees are based on:

• Material categories (plastic, fiber, glass, metal)
• Weight (kg) per material
• Recyclability

California will implement a robust eco-modulation system, including:

• Bonuses for recyclable monomaterials
• Maluses for hard-to-recycle formats
• Penalties for materials that contaminate the system
• Advantages for higher PCR content

Early fees will be invoiced in August 2026.

How California Varies from Other EPR States

• Plastic component count reporting: More granular than Oregon, Colorado which focused only on weight of material per category
• Unique early-fee structure: Early Fees triggered by 2025 data
• Mandatory source reduction plans: Required only in California for 2026
• Producer Baseline updates: 2023 reporting cycles
  

These differences make California the most operationally complex state for 2026.

How rePurpose Global Helps Producers Comply in California

rePurpose Global’s Packaging Sustainability & Compliance Platform supports:

✔ Component & Sub-Component Mapping

Essential for California’s stricter reporting.

✔ Auto-Mapping to CA Material Categories

Including plastics-by-resin, fiber grades, metals, composites.

✔ One-Click Export of All 2026 CA Reports

Baseline, Producer Supply Report, Source Reduction Plan and more.

✔ Source Reduction Planning

Strategize how to achieve source reduction targets using the approved pathways.

✔ State-Level Sales Allocation

If you do not have exact California sell-through data, rePurpose creates compliant estimation models.

✔ Fee Simulation for 2027 Early Fees

We use 2025 data to forecast likely August 2026 invoices.

✔ Harmonization Across All States

Single dataset → mapped into CA, OR, CO, WA, MN, MD, ME.

Frequently Asked Questions 

When are California’s 2026 EPR reports due?

• Final 2023 Baseline Report: ~April 2026, 30 days after regulations finalize
• 2025 Producer Supply Report and Annual Source Reduction Report: May 31, 2026
  
• Individual Source Reduction Plan: Date TBD, but no later than Aug 1, 2026

When are California’s 2026 fees due?

August 2026, based on CY 2025 data.

Do I need a Source Reduction Plan in 2026?

Yes — every producer must submit one. Exact timing TBD.

Does California require sub-component reporting?

Yes. Packaging must be broken down to the component and often sub-component level for plastics.

Can I still submit my 2023 Baseline Report if I’m late?

Yes — the CAA portal remains open for late submissions.

How is California different from Oregon or Colorado?

It requires more granular reporting, includes early-fee structures, and mandates individualized source reduction plans.