California’s Extended Producer Responsibility (EPR) law, Senate Bill 54 (SB 54), is now in effect with significant implications for lubricant manufacturers, brand owners, distributors and private-label sellers doing business in California.

The law shifts responsibility for managing packaging waste from local governments to producers and establishes ambitious statewide goals for reducing and recycling single-use packaging by 2032. Common lubricant packaging such as HDPE motor oil bottles and jugs likely fall within the law’s scope.

The first major compliance deadline passed on June 1, requiring covered producers to register through Circular Action Alliance (CAA), register independently with CalRecycle, or claim a small-producer exemption. Companies that have not yet taken action should do so immediately, as penalties can reach up to $50,000 per day per violation after notice from CalRecycle.

Additional key deadlines include:

• June 15, 2026: CAA submits its program plan to CalRecycle.
• July 1, 2026: Producers must submit 2023 baseline packaging data.
• January 1, 2027: Full EPR program implementation and fee assessments begin.

Members should evaluate whether they qualify as a “producer” under SB 54, assess which packaging materials are covered, gather required baseline data, and begin planning for long-term packaging compliance and recyclability requirements.

While several legal challenges to packaging EPR laws and related California regulations remain pending, ILMA recommends members continue pursuing compliance. Litigation outcomes may affect certain requirements, but they do not eliminate current obligations or enforcement risks.

Compliance guidance, including a detailed explanation of producer responsibilities, registration options, deadlines, litigation developments and recommended next steps are available on ILMA’s Reports & Guidance page (members only access).