U.S. Packaging EPR Atlas Extended Producer Responsibility Intelligence Hub

What changed in the week of October 12, 2026

3 regulatory and policy changes and 1 site update. Entries carry the state or jurisdiction affected and the source that supports them.

Regulatory and policy

Regulatory  |  CA
CAA Submits Final Draft California Plan to CalRecycle
Circular Action Alliance submitted its final draft SB 54 program plan to CalRecycle on October 13, 2026, and CAA’s schedule has CalRecycle approving it on or before January 1, 2027.

What it means for producers: the plan proposes one 2027 fee rate for each covered material category instead of the June draft’s low-to-high ranges. Every rate matches the preliminary schedule CAA published on October 1, which the Atlas already shows, and none of it is binding until CalRecycle approves the plan. CalRecycle must act within 75 calendar days of receiving the plan (14 CCR 18980.6.1(b)(2)). Under the plan, fee invoices go out in January of the program year with 45 days to pay, and for 2027 CAA’s October 1 schedule splits annual fees half in January and half in July and bills the full-year Plastic Pollution Mitigation Fund portion in January. For 2027, a category on the plan’s bonus list (Chapter 10, Table 4) gets a 5 percent bonus on its base fee. That list takes categories with a recycling rate of at least 30 percent on CalRecycle’s list, leaves out any CalRecycle designates non-recyclable or non-compostable and every aluminum category, and the plan says categories with high commodity values may not qualify. A category CalRecycle designates as neither recyclable nor compostable pays a 5 percent malus, and both apply automatically to the supply you reported for 2026 and are already included in CAA’s published 2027 fee rates. CAA does not intend to add eco-modulation factors for 2028, and it plans active factors from 2029 fees, including a malus on packaging features that disrupt recycling, such as undetectable carbon black. Under the plan, a CalRecycle de minimis decision applies only to future supply reports, so it would not reopen your baseline or earlier reports. CAA also says the per-component mitigation fund fee will increase if de minimis rulings sharply cut the number of plastic components reported. The plan proposes 2027 source reduction bonuses of $500 a ton for cutting plastic below your 2026 supply and $1,500 a ton below your 2023 baseline, paid on 2029 invoices. An estimated malus of $100 a ton on all virgin plastic supplied in 2027 funds those bonuses, and CAA is applying for an exemption from the 2027 source reduction targets, which it says it will almost certainly miss.

What to do now: check each category you report against the plan’s lists of bonus and malus categories for 2027 (Chapter 10, Tables 4 and 5). In January 2027 you would receive the full-year mitigation fund invoice and the first half of your other annual fees, each payable within 45 days of receipt, so put both in the budget. The plan also requires you to attest in your annual source reduction report that any recycled plastic you claim is certified to the APR program and contains no added PFAS. The one-page summary of what changed for producers downloads with a free EPR Atlas account from the California page. Sources: CAA release, October 13, 2026; CAA California Program Plan, submitted to CalRecycle October 13, 2026; CAA public comment summary and response (Appendices C and D); CAA 2027 California Producer Fees Schedule (October 1, 2026).
Litigation  |  CO
Auto Care Association Moves to Join NAW's Challenge to Colorado's EPR Law
On October 15, 2026, the Auto Care Association asked the federal court in Denver for permission to intervene as a plaintiff in NAW v. Ryan, the National Association of Wholesaler-Distributors’ challenge to Colorado’s packaging EPR program, and attached a proposed complaint of its own. Judge Philip A. Brimmer referred the motion to Magistrate Judge N. Reid Neureiter on October 16, and, as of October 16, the court had not ruled on NAW’s preliminary injunction motion.

What this means for you: no court order blocks Colorado’s program, so producers should keep planning on the current 2027 dues. Follow the case on the Atlas.

Source: NAW v. Ryan, D. Colo. No. 1:26-cv-03460, ECF 22 to 24 (October 15 and 16, 2026).
Regulatory  |  CA
CAA Takes Comments on Its Draft California Reimbursement Application Through November 3
Circular Action Alliance opened comment on its draft California Reimbursement Application on October 5, 2026, and is taking comments through November 3, 2026. CAA invites local jurisdictions, recycling service providers, Tribes, and other interested parties to review the draft forms.

What this means for you: the application sets how eligible entities will request reimbursement from CAA for covered costs under SB 54. If you are a local jurisdiction, recycling service provider, or Tribe, review the draft before the window closes and submit comments on CAA’s form.

Source: Circular Action Alliance, Reimbursement Application public comment (October 2026).

Site updates

Site Update
New One-Pager on the California Final Draft Plan
A one-page summary of the final draft program plan CAA submitted to CalRecycle on October 13, 2026 is now on the California page, below Program Plan Status. It shows the dates from filing to the first invoice, what changed from the June draft, and the 2027 bonus, malus, and incentives, with the steps producers can take now. It downloads with a free EPR Atlas account, the same account that opens every Atlas tool and download.