California SB 54

California’s SB 54 creates new requirements for companies that use single-use packaging and sell, offer for sale, distribute or import products into California.

Overview of the Issue

California’s Plastic Pollution Prevention and Packaging Producer Responsibility Act, commonly known as SB 54, creates new requirements for companies that use single-use packaging and sell, offer for sale, distribute or import products into California. Along with requirements in other states like Oregon, Colorado, and Minnesota, this is one of several packaging regulations facing brands and retailers.

SB 54 establishes an extended producer responsibility program for single-use packaging and plastic food service ware. The law is intended to reduce plastic packaging, increase packaging recycling and compostability, and shift certain costs associated with packaging waste management from local governments to producers.

For the sportfishing industry, SB 54 is primarily a packaging issue. The law does not directly regulate fishing rods, reels, line, lures, hooks, terminal tackle or related fishing equipment products. However, it may apply to the packaging used to contain, display, protect, ship or sell those products in California.

Examples of packaging that may need to be evaluated include blister packs, clamshells, plastic bags, lure pouches, backing cards, hang tabs, line spool packaging, cartons, shrink wrap, e-commerce mailers, boxes, void fill and other single-use packaging materials.

What Sportfishing Businesses Should Know

SB 54 uses a broad definition of “producer,” which may include manufacturers, brand owners, licensees, importers, distributors, retailers or other sellers depending on the structure of the supply chain and who is selling or distributing the packaged product into California. Companies that sell packaged sportfishing products into California should evaluate whether they may be considered producers under SB 54.

Covered producers generally must either participate in Circular Action Alliance, the approved Producer Responsibility Organization, register with CalRecycle as an independent producer, or qualify for an exemption. Participation in Circular Action Alliance typically means submitting required packaging data, paying applicable fees, and complying with the approved producer responsibility plan.

Small producers with less than $1 million in gross annual sales in California are exempt from obligations under SB 54 but must still register separately with CalRecycle. Other states have similar exemptions based on local or global sales, as well as the amount of packaging sent to a particular jurisdiction.

Key Dates

California’s final SB 54 regulations became effective on May 1, 2026. Producers were required by May 31, 2026, to register with the Circular Action Alliance and submit supply data, register with CalRecycle as an independent producer, or apply for a small-producer exemption.

Although the initial producer registration deadline has passed, companies that sell packaged sportfishing products into California should still act promptly to determine whether they are covered, confirm their registration or exemption status, and prepare for ongoing reporting, fee and packaging-design obligations.

Additional SB 54 milestones include:

  • A 10 percent reduction in single-use plastic packaging by 2027;
  • A 20 percent reduction in single-use plastic packaging by 2030;
  • A 25 percent reduction in single-use plastic packaging by 2032; and
  • Requirements that covered packaging be completely recyclable or compostable by 2032.

Producers must submit Individual Source Reduction Plans by August 1, 2026.

Recommended Next Steps

Sportfishing businesses that sell packaged products into California should review their product lines and packaging to determine whether SB 54 or other state laws apply. Companies may wish to inventory packaging materials by SKU or product category, identify who is responsible for compliance in the supply chain, confirm registration status with the Circular Action Alliance or CalRecycle, and begin evaluating packaging designs that may create compliance or cost challenges over time.

Because SB 54 compliance depends on company-specific facts, ASA encourages members to consult with legal counsel or other qualified compliance professionals when evaluating their obligations. Companies that may be covered producers and did not act by the May 31, 2026, deadline should promptly assess their obligations, register or apply for an exemption as appropriate, and consult legal counsel or a qualified compliance professional. Failure to comply with SB 54 may expose covered entities to enforcement and administrative civil penalties.

For additional information, ASA members may contact Vice President of Government Affairs Mike Leonard at mleonard@asafishing.org.