What’s Next After SB 343? Understanding California’s SB 54 Packaging Requirements

For many brands, California’s SB 343 has been the primary focus of packaging compliance discussions over the past several years. The law fundamentally changed how recyclability claims can be made by establishing strict standards for what packaging can legally be labeled as “recyclable.”

But SB 343 is only part of California’s broader effort to transform the packaging industry.

Now, attention is shifting to SB 54, California’s Extended Producer Responsibility (EPR) law that places greater accountability on producers for the environmental impact of packaging throughout its lifecycle.

For brands selling products into California, understanding how SB 54 builds upon SB 343 is becoming increasingly important.

Officially known as the Plastic Pollution Prevention and Packaging Producer Responsibility Act, SB 54 was signed into law in 2022 and represents one of the most comprehensive packaging regulations in the United States.

Unlike traditional waste management systems that place responsibility on local governments and taxpayers, SB 54 shifts much of that responsibility to producers, including brands, manufacturers, and importers that place covered materials into the California marketplace.

The law applies to most forms of single-use packaging, including:

The goal is to encourage more sustainable packaging design while funding improvements to recycling infrastructure throughout California.

Many companies view SB 343 and SB 54 as separate regulations. In reality, they are closely connected.

SB 343 focuses on labeling and recyclability claims.

SB 54 focuses on producer responsibility and packaging system performance.

The critical connection is that SB 54 relies heavily on the recyclability standards established under SB 343.

In simple terms:

SB 343 determines what packaging can legally be called recyclable.

SB 54 uses those same recyclability standards to determine how packaging contributes toward compliance targets and fee structures.

This means that packaging that does not meet SB 343 criteria may create additional compliance challenges under SB 54.

For many brands, packaging redesign efforts that began because of SB 343 may also support future SB 54 compliance goals.

California has established several ambitious targets that producers will need to support through the EPR program.

By 2032:

These goals are intended to reduce packaging waste while encouraging more circular packaging systems.

What Producers Are Required to Do

Companies subject to SB 54 have several responsibilities.

Join a Producer Responsibility Organization

Producers must participate in the state’s approved Producer Responsibility Organization, the Circular Action Alliance.

The organization is responsible for helping implement and manage compliance requirements on behalf of participating producers.

Submit Packaging Data

Producers must report information regarding packaging materials placed into the California market.

This data helps establish program baselines and informs future fee structures.

Pay Eco-Modulated Fees

One of the most significant aspects of SB 54 is the use of eco-modulated fees.

Under this system:

This creates a strong financial incentive for brands to improve packaging recyclability.

Support Recycling Infrastructure

Fees collected through the program help fund:

As of May 2026:

While some requirements are still being implemented, brands should not wait until fee collection begins to evaluate their packaging portfolios.

How SB 54 Could Impact Packaging Decisions

For many companies, SB 54 may influence packaging decisions in several ways.

Increased Costs for Problematic Packaging

Packaging that is difficult to recycle may become more expensive due to higher eco-modulated fees.

Greater Focus on Packaging Design

Packaging teams may need to evaluate:

Supply Chain Planning

Companies may need to work closely with packaging suppliers to understand material choices, recyclability performance, and future compliance implications.

If your products are sold in California, now is a good time to begin preparing.

1. Inventory Your Packaging Portfolio

Identify all packaging currently entering the California market.

2. Confirm Registration Requirements

Determine whether your organization must participate through the Circular Action Alliance.

3. Evaluate Packaging Against SB 343 Criteria

Review labels, sleeves, adhesives, and package components to understand recyclability performance.

4. Budget for Future Compliance Costs

Eco-modulated fees may affect future packaging budgets and sourcing decisions.

5. Monitor Regulatory Updates

California’s packaging regulations continue to evolve, making ongoing monitoring essential.

Packaging regulations continue to become more complex, and many brands are finding that sustainability and compliance can no longer be treated as separate initiatives.

At Inovar, we work with brands to evaluate label and packaging solutions that support both packaging performance and recyclability goals. Through our portfolio of APR Design® Recognized label constructions, technical expertise, and packaging consultation services, we help customers navigate evolving requirements while maintaining shelf appeal and operational efficiency. As SB 54 implementation continues and SB 343 requirements remain in effect, early planning can help reduce compliance risks, minimize future costs, and position brands for long-term success.