On September 22, 2025, we attended Circular Action Alliance’s (CAA) Quarterly Update webinar. CAA is the Producer Responsibility Organization that has been selected by states with active plastic and packaging Extended Producer Responsibility (EPR) laws to lead their programs.
Key Takeaways:
- California’s plastic and packaging EPR law, Senate Bill 54, continues to face delays in implementation. CAA initially planned to open the portal for producers to report their data in early September, but the portal is still not open. CAA stated during the webinar that they expect the portal to open any day now. Several attendees asked if the reporting deadline of November 15, 2025, would be extended because of the portal opening delays, but CAA did not respond. As it stands, all affected producers are being asked to report their relevant 2023 supply data by November 15.
- Starting in 2026, CAA plans to line up each state’s reporting deadline on the same date, May 31, 2026, to allow for a more streamlined procedure across all states with EPR programs.
We are closely following EPR developments around the country and will continue to provide relevant updates.
