California's 2027 fee is calculated from your 2026 data

SB 54 fees start in January 2027. What you report during 2026 is the input. That makes this year's accuracy a pricing decision, not a paperwork one.

Last reviewed 27 July 2026 · Packfile is not a law firm and this is not legal advice

California is the largest single line in almost every US producer’s packaging EPR exposure — roughly 11.5% of the country by population, against Oregon’s 1.25%. Its fees begin in January 2027. The part that catches people out is that the invoice is calculated from data reported during 2026, which means the accuracy of this year’s submission is not a compliance detail. It is the input to next year’s bill, and an overstated weight is money paid every year until somebody corrects it.

The 2026 dates that matter

1 Jun 2026	Producer registration, or small producer exemption application, due — passed. Late registration is still better than none.
1 Jul 2026	Baseline producer report using 2023 data.
1 Aug 2026	Individual source reduction plans.
1 Jan 2027	Fees begin. First statutory source reduction milestone: 10%.
2030	20% source reduction.
2032	25% source reduction; 65% recycling rate for covered plastic.

Compiled from Holland & Knight’s summary of the final regulations and CalRecycle.

How the fee is built

The formula across all US programmes is the same: tonnage × base rate for that material × an eco-modulation multiplier. Two consequences follow, and both are actionable now.

Weight is the multiplicand. A 5% reduction in the gram weight of your heaviest component reduces the fee by 5% — permanently, in every state, every year. Light-weighting has always paid for itself in freight; now it pays twice.

Material choice swings the rate by more than twenty to one. Oregon is the only state to have published per-material rates so far, and the spread is stark:

Material	Rate	Basis
Expanded polystyrene (EPS foam)	$1.38/lb	published
PVC / PVDC	$1.20/lb	modelled
Polystyrene rigid	$1.10/lb	modelled
Multi-layer laminate / stand-up pouches	$1.02/lb	published
Certified compostable plastics	$1.00/lb	modelled
Mixed / unclassified	$0.75/lb	modelled
PET — coloured bottles and thermoforms	$0.45/lb	modelled
PE film (poly mailers, shrink, bags)	$0.43/lb	published

Rates as published for Oregon’s 2026 programme year, or modelled where no per-material figure has been published. See our packaging weight reference for the full table and the tolerance on each figure.

The most expensive line in most catalogues is the one nobody classified. Packaging reported as “plastic” or “mixed” is charged at an unclassified penalty rate. Resolving an ambiguous film to PE or PE/PET laminate can cut that line by more than half and costs one email to a supplier. It is the cheapest saving available and it requires no packaging change at all.

Source reduction is a separate workstream

SB 54’s fee obligation and its source reduction obligation are not the same thing and do not run on the same clock. The reduction targets — 10% by 2027, 20% by 2030, 25% by 2032, measured against a baseline — apply to plastic covered material and require a plan, not just a payment. Notably, CalRecycle has confirmed that a small producer exempt from reporting and fees is not exempt from the requirement that all covered packaging be recyclable or compostable by 2032.

Want your own number before the 2027 invoice arrives? The free exposure check gives you a screening estimate in ninety seconds. If you want the version built from your actual catalogue — component by component, with a confidence flag on every line — that is our $149 determination.

Run the free check

More on this

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