Packaging EPR Update: Week of June 15, 2026

Comment Period  |  CA

Circular Action Alliance submitted its draft five-year California Program Plan to the SB 54 Producer Responsibility Advisory Board on June 15, 2026. A 60-day public comment period is open from June 15 through August 14, 2026, after which CAA has 60 days to respond before filing a revised plan (expected October 2026) for CalRecycle approval ahead of the January 1, 2027 program start. The Advisory Board discussed the draft plan at a public meeting on June 26, 2026. CalRecycle published the statewide needs assessment synthesis report on February 18, 2026 (Publication DRRR-2026-1774); producers and environmental advocates have flagged the plan's compressed development timeline as limiting public input. Producers can review the plan and submit comments through the CAA California program plan public comment page. Source: Circular Action Alliance (July 2026); Resource Recycling (June 15, 2026).

Litigation  |  OR

On April 1, 2026 the U.S. District Court for the District of Oregon denied motions to intervene in NAW v. Feldon filed by the American Forest and Paper Association (AF&PA) and a group of retail associations (Oregon Business and Industry, the Northwest Grocery Association, and Food Northwest), finding the motions untimely and prejudicial to the expedited July 13, 2026 trial. The court reaffirmed that its February 6, 2026 preliminary injunction shields NAW member companies only; all other producers remain fully subject to Oregon DEQ enforcement. Source: Packaging Dive; Recycling Today; Resource Recycling (April 2026). Update, October 7, 2026: the court ruled for the DEQ Director on August 27, 2026, holding that the Recycling Modernization Act does not violate the dormant Commerce Clause or the Due Process Clause (ECF 205), and entered judgment for the Director on August 28, 2026 (ECF 206). NAW appealed to the Ninth Circuit on September 24, 2026 (No. 26-6404). The ruling removed the basis on which the February 6, 2026 preliminary injunction was granted, though ECF 205 mentions the injunction only in its procedural history, ECF 206 does not mention it, and no order has expressly lifted it, although a preliminary injunction ordinarily does not survive a final judgment against the party that obtained it. (Corrected October 12, 2026.)

Site Update

Several features launched this week: (1) the fee calculators now use California's draft 2027 EPR base fee schedule, sourced from CAA's program plan (Table 5) filed June 15, 2026, with final rates expected October 2026. (2) The Total EPR Fee Estimator added more material categories (gable-top and aseptic cartons, molded fiber, PP and BOPP film, coated paperboard) and a per-state eco-modulation reference panel. (3) A new "EPR fees by state" summary was added to the fee calculator guide. The hub also moved to a cleaner, more consistent layout across all tabs. Source: EPRAtlas.com.

Update, October 7, 2026: CAA published its 2027 California Producer Fees Schedule on October 1, 2026. It states that the 2027 rates “remain preliminary pending regulatory approval of the California program plan and should be considered non-binding until that process is complete,” so final rates did not arrive in October.