In August 2021, California signed its Extended Producer Responsibility law. This legislation targets various materials, such as packaging (package-like products and reusable packaging) and food serviceware. The legislation mandates compliance starting July 2025 and designates Circular Action Alliance as the registered Producer Responsibility Organization (PRO).
Under this law, a “producer” is defined as the manufacturer and owner of a brand or trademark; in their absence, the licensee assumes responsibility. If the product is not manufactured within the state, the importer or distributor bears responsibility. Producers had to register by July 1, 2024, to comply with these new regulations.
On January 8, 2024, Circular Action Alliance (CAA) was formally designated by CalRecycle as California’s first and sole PRO. In addition to administering producer compliance, the PRO is responsible for collecting and remitting significant annual payments to the state beginning in 2027 through 2037, which will be directed toward statewide plastic pollution mitigation and environmental restoration efforts.
If your company sells into California, this may affect your reporting, internal data collection, packaging decisions, and long-term compliance planning.
Depending on your role in the supply chain, your organization may be considered the obligated producer. That responsibility can fall to the brand owner, trademark owner, licensee, importer, or distributor. For many companies, the real challenge is not just understanding the law — it is figuring out who is responsible internally, what information is needed, and how to prepare without overloading already stretched teams.
California is also setting the tone for how packaging EPR is evolving across the U.S. What starts in one state can quickly become part of a much larger operational and financial burden
The best time to prepare is before compliance pressure builds. A practical first step is to confirm whether your company is obligated and identify what data, teams, and systems will be needed to respond.
From there, organizations should begin reviewing:
Getting ahead now can reduce compliance risk, prevent last-minute reporting pressure, and help your team build a more manageable path forward
We help producers make sense of complex EPR requirements and turn them into practical action.
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