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As California continues implementing the Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54), CalRecycle has released updated producer guidance to help businesses navigate extended producer responsibility (EPR) compliance.

If your aquaculture operations involve packaging seafood, fish products, or food service items in single-use plastic, glass, paper, or metal, these regulations may directly impact your business.

Key Requirements & Statutory Targets

SB 54 requires producers of single-use packaging and plastic food service ware to achieve ambitious source-reduction and recycling benchmarks:

• Jan 1, 2027: 10% reduction in single-use plastic packaging
• Jan 1, 2028: 30% of single-use plastic recycled
• Jan 1, 2030: 20% reduction & 40% recycled
• Jan 1, 2032: 25% reduction, 65% recycled, and 100% of packaging must be recyclable or compostable

Three Compliance Options for Producers

Under the law, businesses identified as “producers” of covered materials must take one of three paths:

1. Join the Producer Responsibility Organization (PRO): Join Circular Action Alliance (CAA), the state-approved PRO that manages registration, fee collection, reporting, and compliance on behalf of participating producers.
2. Apply as an Independent Producer: Submit an independent plan directly to CalRecycle detailing how your business will meet recycling and source-reduction goals individually.
3. Claim a Small Producer Exemption: Businesses meeting specific low-volume or small-revenue thresholds may apply for an exemption.
   • Revenue Limit: Gross California sales/revenue of less than $1,000,000.
   • Volume Limit: Introduced less than 1 metric ton (2,205 lbs) of covered single-use packaging or food service items into California commerce.

Important Considerations for Seafood & Ag Producers

• Food & Agricultural Commodity Exclusions: CalRecycle has provided specific guidance for submitting a Categorically Excluded Materials Notice for Food and Agricultural Commodity Packaging. Aquaculture producers should review these definitions carefully to determine if certain primary packaging qualifies for an exclusion.
• Reporting via PEPRS: Registration, baseline reporting, and compliance documentation are managed through CalRecycle’s online portal, the Packaging Extended Producer Responsibility System (PEPRS).

Next Steps for Aquaculture Businesses

1. Audit Your Packaging: Determine if your packaging falls under “covered materials” using CalRecycle’s situational screening tool.
2. Check Exclusions: Review the guidance for agricultural and food commodity packaging to see if your products qualify.
3. Register/Evaluate Compliance Options: Prepare to register in PEPRS or connect with Circular Action Alliance prior to upcoming reporting windows.

For complete documents, toolkits, and registration portals, visit the CalRecycle Producer Guidance Page or contact CalRecycle directly at Packaging@calrecycle.ca.gov.