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).