Guide to CA packaging laws

SB 54: Extended Producer Responsibility for Packaging

SB 54 creates California's first EPR program for single-use packaging. Signed in June 2022, it shifts recycling costs from cities to the companies that create packaging.

Deadline: January 1, 2027 (registration)

Your Requirements

  • Join the Circular Action Alliance (CAA) by January 1, 2027. This is California's approved Producer Responsibility Organization.
  • Submit annual packaging data starting with 2023 baseline: material types, weights, and SKUs. First report deadline was November 15, 2025.
  • Pay eco-modulated fees starting in 2027. Fees vary based on recyclability. Hard-to-recycle materials pay more.
  • Redesign packaging by 2032 to be recyclable or compostable under California infrastructure.

Example: Coffee Bags

  • Metallized bags (aluminum laminated with plastic/paper) aren't recyclable in California's system. You'll pay higher fees and need to redesign by 2032. Options: mono-material recyclable film or certified compostable alternatives.

The 2032 goals

  • 100% of single-use packaging recyclable or compostable
  • 65% plastic packaging recycling rate
  • 25% reduction in single-use plastic by weight

SB 343: Truth in Recycling Labeling

SB 343 bans the ♻ symbol and "recyclable" claims unless your packaging meets strict criteria based on actual collection and sorting rates.

Deadline: October 4, 2026 (compliance)

Your Requirements

  • Audit packaging labels. Remove ♻ symbols or "recyclable" claims if materials don't meet the 60/60 threshold.
  • Document everything. Keep supplier specs, material certifications, and recyclability pathway documentation. You must make this documentation available to any member of the public who requests it.
  • Handle multi-material carefully. Each component needs separate assessment. A poly mailer might qualify, but a glossy coated insert likely doesn't.

Example: Poly Mailers with Inserts

  • Your LDPE poly mailer may be recyclable, but the lining inside may not be. Don't put the ♻ symbol on the insert. Use uncoated paper or mark it "not recyclable."

To be recyclable in California:

  • Collected by programs serving 60%+ of the state's population
  • Sorted by facilities serving 60%+ of those programs
  • **CalRecycle's April 2025 Material Characterization Study identifies which materials qualify.

AB 1201: Compostable Labeling Requirements

AB 1201 restricts "compostable" labels to packaging meeting multiple certification standards.

Deadline: June 30, 2027

Your Requirements

  • Verify certifications. Confirm BPI certification, USDA NOP compliance, and PFAS test results.
  • Maintain documentation. Provide proof to any member of the public who requests it.
  • Remove non-compliant claims by June 30, 2027.

Example: Compostable Poly mailers

  • Your BPI-certified compostable poly mailer may be industrially compostable, but if it doesn’t meet USDA NOP requirements or PFAS limits, you cannot call it “compostable” in California after June 2027. You’ll need to verify full compliance or adjust your labeling.

Requirements for "compostable" claims:

  • ASTM D6400/D6868 certification (industrial) or OK Compost HOME (home compostable)
  • USDA National Organic Program (NOP) compliance
  • PFAS-free (below 100 ppm)
  • The problem: Most compostable plastics (PLA, PHA) don't meet USDA NOP requirements. Only certain uncoated paper and plant-fiber materials qualify.

AB 347: PFAS Restrictions in Food Packaging

AB 347 strengthens PFAS bans in food packaging, juvenile products, and textiles. PFAS ("forever chemicals") are banned above 100 ppm in plant-fiber food packaging.

Deadline: July 1, 2030 (enforcement begins)

Your Requirements

  • Test materials. Get PFAS test results from suppliers, especially for grease-resistant coatings. Testing costs $300-$1,500 per sample.
  • Register by July 1, 2029 with California's Department of Toxic Substances Control (DTSC).
  • Source PFAS-free alternatives if levels exceed 100 ppm.
colourful donut box

Example: Grease-Resistant Boxes

  • Pizza boxes often use coatings containing PFAS. If your coating exceeds 100 ppm, switch to PFAS-free alternatives like aqueous coatings. Start now—reformulation takes time.

Action Steps

Action Steps

  1. Audit your packaging List every SKU sold in California. Document materials, labels, and supplier certifications.
  2. Check recyclability (SB 343) Cross-reference materials against CalRecycle's study. Remove non-compliant ♻ symbols.
  3. Verify compostable claims (AB 1201) Confirm ASTM/BPI certification, USDA NOP compliance, and PFAS test results. Remove claims if you can't meet all requirements.
  4. Test for PFAS (AB 347) Request test results for plant-fiber food packaging. Source alternatives if needed.
  5. Register for SB 54 Join the CAA by January 1, 2027. Gather 2023 packaging data and budget for annual fees.
  6. Redesign packaging Shift to mono-materials, materials meeting SB 343 criteria, PFAS-free options, and certified compostables meeting NOP requirements.
  7. Update labels Remove non-compliant symbols and claims. Add accurate disposal instructions.

Why This Matters

These laws push California toward a circular economy. For your brand:

  • Risk mitigation

    Non-compliant labeling is showing up in litigation.

  • Consumer trust

    Accurate claims build credibility.

  • Market access

    Other states are following California's lead.

  • Efficiency

    Simplified packaging often reduces costs while improving recyclability.

Need Help?

At EcoPackables, we specialize in sustainable packaging that meets California's requirements. We offer recyclable mono-materials, certified compostable options, and PFAS-free alternatives.

Ready to get compliant? Contact EcoPackables today.

Contact Us