California SB 54 Update: Proposed Regulations Were Withdrawn, Here’s What to Do Next
If you’re tracking California SB 54 (packaging EPR), here’s the update that matters this week: CalRecycle withdrew the proposed SB 54 regulations from OAL review on January 9, 2026. They said they pulled it back to revise for clarity - especially around food and agricultural commodities - and they’re planning to reopen another 15-day public comment period (timing hasn’t been posted yet).
This doesn’t mean SB 54 is going away. It means the regulatory “how” is still being tightened up, and the timeline we all assumed was coming next may shift. CalRecycle’s messaging has also been that statutory deadlines remain unchanged, even as the regulations get refined.
So, what do we do with that?
What This Means in Plain English
When regulations move, teams tend to do one of two things:1. Pause - because "it's not final"
2. Scramble later when the window opens, and you relize your data isn't clean
Neither one feels good.
In my experience, the fastest way to get burned is waiting until the last minute to hunt down packaging details you should’ve had locked down months ago - especially when those details live across suppliers, internal specs, and “tribal knowledge.”
This is the moment to get your foundation right.
What's Recommend Producers Do Right Now
Here’s the practical list - packaging engineer style:
1. Get your packaging BOM into "EPR-ready shape"
Not Perfect. Not Beautiful. Just traceable and defensible.You want to be able to answer, quickly:
- What's the packaging format?
- What are the components?
- What are the weights?
- What assumptions did we use?
2. Make your "missing info" list (and be honest)
Common gaps seen:- Component weights (especially labels, liners, closures, tiny parts)
- Coatings and/or layers
- Adhesives and inks documentation
- PCR documentation and traceability
3. Decide who owns supplier outreach and validation
Because here's the truth: Suppliers don't always have what you need "on request", and you don't want to discover that two weeks before a deadline.
4. Build a simple rapid-response plan for when the comment window opens
When the 15-day public comment period drops, you'll want a quick internal process: - Who reads the changes?
- Who maps it to our packaging/reporting categories?
- Who decides if we submit comments?
- Who updates our internal tracker and comms?
5. Monitor authoritative sources weekly (not daily panic-scrolling)
Weekly is enough if you're consistent. The point is catching changes early, not after your inbox is on fire.
What to Watch Next
Here are the next "watch items" that will matter: - When CalRecycle announces the 15-day comment period dates
- When the revised package is resubmitted to OAL
- Any clarification that hanges definitions or reporting expectations for food/ag packaging
How Adept Can Help - Without Making This Complicated
Adept helps teams set up EPR so it’s repeatable and not dependent on one person’s brain.That usually looks like:
- Packaging data cleanup and gap closure plan
- Supplier request templates (waht to ask for and how to validate)
- Reporting templates and QA checks
- Weekly monitoring summaries that translates "regulatory" into "what we do next"
Bottom line: Regs shifted, but readiness shouldn't pause. Use this time to tighten your packaging data foundation so you can move fast when the next SP 54 update lands.
Disclaimer: Informational only; not legal advice
About the Author: Keshia Mack, a Senior Packaging Engineer with Adept Group, supports CPG clients across packaging development, sustainability, and regulatory compliance. She brings a practical, detail-driven approach to helping teams align packaging decisions with evolving requirements and business needs.