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California's final program plan: a smaller budget, the same 2027 rates

Circular Action Alliance (CAA), the producer responsibility organization (PRO) that runs SB 54, sent its final program plan to CalRecycle on October 13. The 2027 budget is about $1.1 billion, down from as much as $1.87 billion in the June draft. The preliminary 2027 rates are unchanged.

Producer DeskOctober 19, 2026California

What changed

On October 13, 2026, CAA submitted its final SB 54 program plan to CalRecycle, California's recycling agency. The plan sets a 2027 budget of $1.105 billion. The June draft put it at between $1.26 billion and $1.87 billion. CalRecycle has 75 days from receipt to approve, reject or conditionally approve the plan, which runs to around December 27, 2026.1,2

Every 2027 rate in the plan matches the preliminary schedule CAA published on October 1. None of it is binding until CalRecycle approves the plan.3,4

What it means for a mid-size brand

For a food or personal-care brand, the smaller budget doesn't change the 2027 numbers you should plan with. The rates are the same as on October 1, so budget 2027 at CAA's preliminary schedule and check again when CalRecycle acts.3

The timing matters more than the total. Program fees are invoiced in two halves, in January and July 2027. The Plastic Pollution Mitigation Fund charge, 26¢ per pound of plastic plus 0.1¢ per plastic component, is billed for the full year in January.3,4 So for a brand that sells mostly plastic packaging, the January invoice will be well over half of its 2027 California bill. Plan the cash for that.

We've updated the California guide to reflect this.

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Sources

  1. Resource Recycling, “CAA trims first-year SB 54 budget in final plan,” Oct. 13, 2026. resource-recycling.com
  2. Circular Action Alliance, California draft program plan (June 15, 2026). PDF
  3. EPR Atlas, “CAA submits final draft California plan to CalRecycle” (updated Oct. 18, 2026). epratlas.com
  4. Circular Action Alliance, California 2027 fee schedule, preliminary (Oct. 1, 2026). circularactionalliance.org

General information, not legal advice. This note summarizes a public document as we read it on the date above. Check the source before you act on it.