CalRecycle outlines SB 54 regulatory schedule; PROs will reimburse CalRecycle for exclusion reviews
March 18, 2026 | California State Assembly, House, Legislative, California
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CalRecycle Director Zoe Heller briefed the subcommittee on SB 54 implementation and an expedited regulatory timeline. The department closed a 15‑day comment period and aims to file final regulations with the Office of Administrative Law so producer responsibility organization (PRO) plans can meet the June 15 submission deadline; the department must review and act on PRO plans by January 1, 2027.
Heller said the department added specificity in recent drafts to govern categorical exclusions for food and agricultural commodity packaging. Those exclusions are not automatic; producers must submit a notice that explains the federal conflict they believe prevents compliance, and CalRecycle will evaluate the demonstration. For materials that cannot show compliance pathways in the near term, Heller said the department expects more exemptions and that those would be incorporated into the PRO plan with a path toward future compliance.
On costs, Heller said "anything that CalRecycle does under the law is reimbursed by the producer responsibility organization," and the department expects PROs to cover evaluation work for exclusion notices. CalRecycle also has created a needs assessment document to help the PRO determine infrastructure and collection needs and will apply strict criteria for "responsible end markets" for chemical recycling or other nonstandard recycling pathways.
Members asked about appeal timelines, clarity of hazardous‑waste treatment versus recycling pathways, and whether the department can keep to the calendar; CalRecycle said timelines are tight but achievable and that some regulatory criteria for responsible end markets are still being finalized via the PRO plan review process.
Heller said the department added specificity in recent drafts to govern categorical exclusions for food and agricultural commodity packaging. Those exclusions are not automatic; producers must submit a notice that explains the federal conflict they believe prevents compliance, and CalRecycle will evaluate the demonstration. For materials that cannot show compliance pathways in the near term, Heller said the department expects more exemptions and that those would be incorporated into the PRO plan with a path toward future compliance.
On costs, Heller said "anything that CalRecycle does under the law is reimbursed by the producer responsibility organization," and the department expects PROs to cover evaluation work for exclusion notices. CalRecycle also has created a needs assessment document to help the PRO determine infrastructure and collection needs and will apply strict criteria for "responsible end markets" for chemical recycling or other nonstandard recycling pathways.
Members asked about appeal timelines, clarity of hazardous‑waste treatment versus recycling pathways, and whether the department can keep to the calendar; CalRecycle said timelines are tight but achievable and that some regulatory criteria for responsible end markets are still being finalized via the PRO plan review process.
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