California’s packaging EPR program comes from SB 54 (the Plastic Pollution Prevention and Packaging Producer Responsibility Act). It creates an extended producer responsibility system for single-use packaging and single-use plastic food service ware, with CalRecycle overseeing the program and a Producer Responsibility Organization (PRO) running it day to day.

CalRecycle has approved Circular Action Alliance (CAA) as the first PRO for SB 54.

Why “baseline packaging data” is such a big deal

In an EPR system, the program needs reliable numbers to function. Baseline data is essentially the starting point that supports:

• fairer fee setting,
• program planning and budgeting,
• tracking progress against SB 54 requirements over time.

So the “baseline report” isn’t a box-ticking exercise – it’s the dataset the system builds on.

What to expect starting in 2026

California’s SB 54 rulemaking is still evolving, but the draft regulations are clear on the overall direction: data reporting becomes an annual requirement starting in 2026, and reports are intended to be due July 1 each year (with data covering the prior calendar year).

Separately, industry updates also point to the practical reality that once the final regulations are adopted, producers may need to reconfirm or adjust their baseline figures so the “official” numbers match the final definitions and scope.

Keeping it manageable

A simple, workable approach usually looks like this:

• Confirm whether you’re a “producer” for California.
• Join/coordinate with the PRO (CAA) and follow their reporting guidance as it’s issued.
• Build one packaging dataset you can maintain (materials, formats, weights, and product mapping).
• Assign one internal owner for the reporting numbers, with packaging/supply chain/finance supporting.

How Viron Compliance Ltd helps

Viron Compliance Ltd supports companies with California packaging EPR by keeping it practical: producer scoping, PRO onboarding support, packaging data structuring, and baseline reporting preparation that stays stable even when SKUs and suppliers change.