On June 15, 2026, Circular Action Alliance (CAA) submitted its draft program plan (draft plan) to CalRecycle’s extended producer responsibility (EPR) program advisory board, with Chapter 9 of the draft plan revised and posted for public access on June 18, 2026. CAA was required to submit this plan under California’s Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54), the state’s EPR law. The draft plan, which outlines how the state will achieve requirements set out in SB 54, is an important step toward implementation of the program. The public comment period for the draft plan is open until August 14, 2026.
CAA Background
CAA, incorporated on December 21, 2022, is the Producer Responsibility Organization (PRO) tasked with developing and implementing many aspects of California’s EPR program. CAA has also been approved as the PRO or has applied to be the PRO in most states with existing packaging EPR programs. While some states require that producers join a PRO, California’s EPR program allows producers to voluntarily join the PRO as part of the compliance requirements under SB 54.
CAA was established specifically to support and help implement EPR programs for plastic and packaging. The founders of the organization are producers of value chains such as retail, consumer goods, food, and others where plastic and packaging are prevalent. Additional information about CAA can be found on its website.
Overview of Draft Plan
CAA states that the purpose of the draft plan is to “…achieve source reduction, expand recycling infrastructure and support the development and maintenance of viable responsible end markets.” The draft plan includes background data to establish baselines, projections and likelihoods, and CAA’s action plans and next steps to achieve various compliance goals. The draft plan splits key elements of compliance into 12 chapters. Chapters and highlights from the respective chapters include:
- Chapter 1: Equitable Access, Participation and Environmental Justice
- CAA notes that SB 54 calls out explicitly that certain groups and communities are disproportionately impacted by plastic pollution and other related environmental harms.
- CAA is taking steps to improve access to materials, assistance, and information, and is giving consideration to environmental justice issues as program implementation moves forward.
- CAA notes that SB 54 calls out explicitly that certain groups and communities are disproportionately impacted by plastic pollution and other related environmental harms.
- Chapter 2: Reimbursement and Payment Process
- Under the reimbursement process, municipalities, local entities, and utilities can apply for funding for projects related to infrastructure improvement or other actions to further the goals of SB 54.
- Under the reimbursement process, municipalities, local entities, and utilities can apply for funding for projects related to infrastructure improvement or other actions to further the goals of SB 54.
- Chapter 3: Materials Strategy and Covered Material Category Compliance Plan
- Part of CAA’s “action plan” is to phase in materials that align with program goals and are compatible with compliance while phasing out materials that are harder to recycle or otherwise harder to bring into compliance.
- CAA will help design assessment processes and studies to receive continuous data that can be used to ensure data-driven requirements.
- Part of CAA’s “action plan” is to phase in materials that align with program goals and are compatible with compliance while phasing out materials that are harder to recycle or otherwise harder to bring into compliance.
- Chapter 4: Strategy for Compostable Covered Materials
- CAA provides labeling and design guidance for producers of compostable materials covered under SB 54.
- CAA provides labeling and design guidance for producers of compostable materials covered under SB 54.
- Chapter 5: Responsible End Markets
- CAA has developed a three-step program (initial screening, data review, audit) for verifying responsible end markets (REM) that may meet criteria established under SB 54.
- CAA includes REM eligibility criteria for non-mechanical recycling processes, including pyrolysis and depolymerization.
- CAA has developed a three-step program (initial screening, data review, audit) for verifying responsible end markets (REM) that may meet criteria established under SB 54.
- Chapter 6: Source Reduction
- CAA proposes an incentives program for producers to innovate source reduction strategies. This incentives program consists of three types of actions, including a bonus/malus system for producers who are successful in source reduction.
- The chapter lays out CAA’s Reuse and Refill Investment Plan.
- CAA proposes an incentives program for producers to innovate source reduction strategies. This incentives program consists of three types of actions, including a bonus/malus system for producers who are successful in source reduction.
- Chapter 7: Education and Outreach
- CAA bases its education and outreach efforts around three basic questions: what is changing, why does it matter, and how can people participate.
- CAA bases its education and outreach efforts around three basic questions: what is changing, why does it matter, and how can people participate.
- Chapter 8: Budget Development for SB 54 Implementation
- CAA projects a 2027 program budget of up to $1.87 billion. Within the next five years, this budget could expand to between $9.35 billion and $17.2 billion.
- The chapter defines and describes each discrete category of budget costs.
- CAA projects a 2027 program budget of up to $1.87 billion. Within the next five years, this budget could expand to between $9.35 billion and $17.2 billion.
- Chapter 9: Fee-Setting
- Producers of plastics will see raised fees to fund the Plastic Pollution Mitigation Fund. CAA expects to raise $5 billion over the next ten years from producer payments into the Fund.
- The chapter lists fees associated with different materials along with CAA’s methodology for calculating producer fees.
- Producers of plastics will see raised fees to fund the Plastic Pollution Mitigation Fund. CAA expects to raise $5 billion over the next ten years from producer payments into the Fund.
- Chapter 10: Eco-Modulation
- CAA describes two eco-modulation types: active and passive.
- For 2027 fees, CAA proposes to utilize eco-modulation for two categories: source reduction and improve recyclability.
- For future years, CAA proposes additional categories of eco-modulation, including product design.
- CAA describes two eco-modulation types: active and passive.
- Chapter 11: CAA Management and Compliance
- CAA explains its process for managing exclusions and exemptions from various program requirements.
- The chapter covers producer registration, program administration, compliance management, and data management.
- CAA explains its process for managing exclusions and exemptions from various program requirements.
- Chapter 12: Closure and Transfer Plan
- The chapter establishes a procedure to be followed should CAA be dissolved or if an approved program plan is eventually revoked.
- The chapter establishes a procedure to be followed should CAA be dissolved or if an approved program plan is eventually revoked.
Each chapter is robust and contains a large amount of helpful information. The above highlights are not comprehensive of the information contained in the draft plan. Producers with specific interests or questions not addressed above should review the draft plan for information related to that topic.
Commentary
As the foundational elements of plastics and packaging EPR in the United States continue to evolve, California’s program plan will help to shape the state’s program for years to come. As we have seen in other jurisdictions, certain compliance obligations under existing U.S. EPR programs can be burdensome or hard to achieve from a technical standpoint. SB 54 sets the highest goal recycling rate of any existing U.S. program, so we expect to see certain compliance challenges arise due to the high bar set under the law. B&C encourages stakeholders and members of the regulated community to review the draft plan or relevant chapters of the plan and provide comment on elements that raise compliance concerns.
The public comment period is open until August 14, 2026, and comments can be submitted online through CAA’s comment page. CAA will review comments as it prepares to submit the final program plan to CalRecycle by October 2026. To help inform decisions related to the final program plan, CAA is seeking comments that are specific, focus on discrete sections or chapters, help provide clarity or feasibility, and that explain which portions of the draft plan are favorable in addition to noting what CAA should change. CAA provides background about the draft plan and downloadable PDFs of each chapter of the draft plan on its webpage about the public comment period.
CAA also will hold a webinar on the proposed draft plan on July 8, 2026. Those interested in attending this webinar can register using this link.