September 1, 2025
In August 2025, the regulatory climate for cannabis brands in California reached a historic inflection point. The California Department of Resources Recycling and Recovery (CalRecycle) formally opened rulemaking to implement SB 54: Plastic Pollution Prevention and Packaging Producer Responsibility—effectively launching the state’s most ambitious packaging Extended Producer Responsibility (EPR) system to date.
While the food, beverage, and consumer goods industries have anticipated these changes, the cannabis sector faces unique challenges and compliance obligations as cannabis was not exempted from SB 54’s requirements. Every brand placing packaged cannabis products into California’s market must now prepare to overhaul their packaging strategies and compliance procedures to meet the state’s new environmental mandates.
This guide provides a detailed review of CalRecycle’s rulemaking, key requirements under SB 54, and crucial compliance action items for cannabis operators heading into 2026.
SB 54 is a landmark state law enacted to curb plastic pollution by transforming the way packaging is produced, distributed, and managed at end-of-life. Major objectives include:
Crucially, cannabis and hemp brands are not exempt. In 2025 regulatory updates, CalRecycle clarified that any company placing packaged cannabis products on the California consumer market will likely be categorized as a “producer.”
This covers:
“Producer” status brings a host of new obligations—including enrolling in a state-approved Producer Responsibility Organization (PRO), submitting detailed packaging data, and financing packaging collection and recycling via eco-modulated fees.
Action Item: Monitor CalRecycle’s regulatory updates for finalized SB 54 rules, designated PROs, and any grace periods.
SB 54 assigns packaging EPR responsibility to the party that first sells or distributes the packaged product into California. In the cannabis sector, this could be:
Clarify your position: Each company must identify if they are deemed the “producer”—and gather contractual evidence if packaging EPR liability falls elsewhere.
CalRecycle requires component-level packaging data reporting for each SKU. You must:
Pro tip: Rationalize your SKU lineup to streamline reporting and concentrate EPR compliance investments.
The January 2025 CalRecycle Covered Materials Update greatly restricted what’s considered "recyclable" in California’s system. Cannabis brands must:
Warning: “Greenwashing” through unsubstantiated claims can trigger civil penalties and DCC/CDPH enforcement.
Cannabis packaging in California is subject to rigorous child-resistance and THC safety rules—sometimes in tension with CalRecycle’s environmental focus. Cannabis operators should:
Covered producers in the EPR system will pay annual, eco-modulated fees to a designated PRO. Fee models will reward recyclable, low-impact, and source-reduced packaging—while heavily penalizing use of problem plastics and complex multi-material formats.
Cannabis-specific impacts:
Business takeaway: Sustainable packaging is now a regulatory as well as a brand imperative
Once PROs are approved by CalRecycle in 2026, cannabis producers must enroll, accept their annual packaging data, and manage fee payments. Early engagement is recommended:
For more on how PROs work, visit CalRecycle’s SB 54 Resources.
1. Map Your Supply Chain Producer Liability
Document who in your supply chain is legally the “producer” for each packaged product. Prepare to share contracts or certificates with regulators if requested.
2. Collect Component-Level Packaging Data
Work with packaging suppliers to inventory all input materials, weights, and recyclability/compostability attributes.
3. Review and Rationalize SKU Packaging
Eliminate or redesign products packaged with multi-material plastics, films, or non-recyclable components. Prioritize mono-material or paper-based formats that pass MRF (material recovery facility) sortation.
4. Vet All Recycling and Compost Claims
Ensure marketing claims are fully substantiated and compliant with CalRecycle/FTC Green Guides.
5. Coordinate with Cannabis Regulatory Packaging Rules
Cross-check all packaging redesigns with DCC and CDPH/DPH cannabis packaging and labeling rules to avoid conflicts.
6. Engage a PRO Early
Begin initial communication with PROs as soon as they are designated for your sector. Prepare organizational systems for annual data uploads and EPR fee management.
7. Model Cost Impacts and Update Pricing
Forecast and incorporate EPR-related costs into your 2026-2028 pricing and budgets.
8. Monitor Final SB 54 Rule Text
Stay tuned to CalRecycle’s process for grace periods, small producer waivers, and the evolving ruleset.
SB 54 grants CalRecycle new enforcement authority:
Strategic advantage: Early-compliant brands will avoid penalties, win regulator goodwill, and better position themselves for B2B sales as buyers audit packaging compliance throughout the supply chain.
Well-prepared cannabis operators will reap both regulatory and brand rewards in California’s evolving sustainable market.
Need help preparing for SB 54 and EPR compliance?Visit CannabisRegulations.ai for the latest updates, compliance resources, and expert support tailored to cannabis packaging regulations and environmental rulemaking.
