California's packaging Extended Producer Responsibility (EPR) law, SB 54, entered a new phase this spring when CalRecycle, the agency responsible for implementing the law, published approved implementing regulations. While much of the public discussion has focused on consumer packaging and single-use plastics, one of the most consequential developments for the printing and packaging industry is the inclusion of business-to-business (B2B) packaging.
Beyond Consumer Packaging
California's SB 54 regulations extend beyond consumer-facing packaging and covers primary, secondary, and tertiary packaging. This means that certain packaging used within business-to-business supply chains may also be subject to EPR requirements.
As a result, corrugated shipping containers, pallet wrap, stretch film, shrink wrap, protective packaging, and other transport packaging used between businesses may fall within the program's scope, depending on how the packaging is used and whether any exclusions apply.
The implications for packaging converters are significant. A substantial share of packaging produced by the industry never reaches consumers directly as it is used to move products among manufacturers, warehouses, retailers, fulfillment centers, and other commercial customers. Under California's regulations, packaging use in a business environment does not necessarily exclude it from EPR obligations, making it important for printing operations shipping within or into the state to evaluate whether their products are covered.
Growing Compliance Demands
The first major compliance milestone under California's SB 54 program arrived on June 1, 2026, when covered producers were required to register with the state's approved Producer Responsibility Organization (PRO), Circular Action Alliance (CAA). Producers also had the option to apply for approval as an independent producer or seek a small-producer exemption, if eligible.
The next key deadline is July 1, 2026, when baseline producer reporting based on 2023 data is due to CalRecycle. For producers participating in the PRO, this reporting is submitted by CAA on behalf of registered producers using the data provided during the registration process.
In addition to the final regulations, CalRecycle has released supplemental guidance addressing key compliance questions under SB 54. Packaging converters shipping products into California should review both the regulations and agency guidance to evaluate whether their packaging, including certain business-to-business applications, may be covered.
Customer Expectations
Although brand owners generally bear primary responsibility under EPR programs, compliance requirements rarely remain isolated to one party. Even companies that are not obligated producers under SB 54 may find customers requesting detailed packaging data to support compliance reporting and fee calculations.
Printers and converters providing covered packaging should expect increased customer inquiries regarding:
- Material composition
- Recyclability claims
- Recycled content levels
- Packaging weight optimization
- End-of-life management
- Documentation and reporting requirements
Many brand owners have already evaluated their packaging portfolios to understand potential EPR cost exposure. Heavier materials, difficult-to-recycle formats, and complex multi-material structures could face greater scrutiny as producers seek to manage compliance costs. As a result, converters may encounter growing demand for packaging redesign projects, lightweighting initiatives, and recyclable material alternatives.
Looking Ahead
The U.S. packaging industry is only beginning to enter the era of EPR implementation. As state programs move from legislation to compliance, many brand owners are discovering that they do not have all the packaging data required for reporting obligations, fee calculations, and material disclosures.
As a result, EPR compliance is becoming a cross-functional effort that extends beyond sustainability and regulatory teams to include procurement, operations, packaging suppliers, printers, and converters. For converters, this presents a challenge and an opportunity. Those that can serve as a trusted resource by providing accurate, verifiable, and readily accessible packaging data will be better positioned to support customers navigating new reporting requirements
In this article, Sara Osorio, Manager, EHS & Sustainability, PRINTING United Alliance, discusses California’s new EPR regulations. More information on sustainability can be found at Business Excellence-EHS Affairs, or reach out to Sara directly if you have questions about how these issues may affect your business: sosorio@printing.org.
To become a member of the Alliance and learn more about how our subject matter experts can assist your company with services and resources such as those mentioned in this article, please contact the Alliance membership team: 888-385-3588 / membership@printing.org.
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