New legislation creates significant new compliance obligations for companies selling products into California. Here’s why that matters.
Sacramento, Calif.—California’s Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54) has officially entered the implementation phase, creating significant new compliance obligations for companies selling products into California.
While the law has largely been associated with consumer packaged goods, many automotive aftermarket manufacturers may also be subject to its requirements, including those that package lubricants, chemicals, replacement parts, and accessories.
CAWA is issuing this alert to help members understand how the law may affect their businesses and to encourage manufacturers to proactively evaluate their obligations before additional reporting and compliance milestones arrive.
Why SB 54 matter to the automotive aftermarket
SB 54 regulates single-use packaging sold into California — not specific industries or product types. As a result, many automotive products may fall within the law’s scope because of the packaging in which they are sold.
For many CAWA members, this means the law may apply not only to shipping materials but also to the primary packaging that contains automotive products.
Automotive Fluids and Chemicals
▪ Motor oil bottles
▪ Transmission fluid containers
▪ Antifreeze and coolant jugs
▪ Brake fluid bottles
▪ Power steering fluid containers
▪ Windshield washer fluid bottles
▪ Fuel additives
▪ Engine treatments and oil additives
▪ Grease cartridges
▪ Diesel Exhaust Fluid (DEF) containers
Replacement Parts & Accessories
▪ Oil filters packaged in cardboard cartons
▪ Brake pads and rotors
▪ Lighting products in clamshell packaging
▪ Electrical components packaged in plastic bags
▪ Wiper blades
▪ Small repair parts sold in blister packs
▪ Battery accessories and retail packaging
The law may also apply to:
▪ Corrugated cardboard shipping cartons
▪ Plastic bags
▪ Clamshell packaging
▪ Blister packaging
▪ Protective foam
▪ Plastic caps and closures
▪ Labels, shrink sleeves, and other packaging components
Who is responsible?
One of the most challenging aspects of SB 54 is determining who qualifies as the regulated “producer.” Depending on how products are manufactured and distributed, responsibility may fall on:
▪ The brand owner
▪ The trademark owner
▪ The importer
▪ The first entity introducing the packaged product into California
▪ Another entity identified under the statute and regulations
Because many aftermarket manufacturers utilize private-label products, contract manufacturing, distributors, or imported products, determining the responsible party requires careful review.
Current status of implementation
CalRecycle’s permanent SB 54 regulations became effective on May 1, 2026, officially launching California’s Extended Producer Responsibility (EPR) program for packaging.
Initial producer registration has begun through the approved Producer Responsibility Organization (PRO), Circular Action Alliance (CAA), and producers should already be evaluating their reporting obligations.
Implementation activities currently underway include:
▪ Producer registration
▪ Packaging data collection
▪ Material reporting
▪ Development of producer fee methodologies
▪ Ongoing CalRecycle guidance and implementation updates
Key upcoming milestones
2026
Producer registration and packaging reporting continue. Companies should inventory covered packaging sold into California. Additional implementation guidance and reporting requirements are expected from CalRecycle and CAA.
January 1, 2027
California begins implementing the law’s initial source reduction requirements, marking the first phase of statewide packaging reduction targets.
2028–2032
Requirements become increasingly stringent, including higher recycling performance standards, source reduction requirements, packaging redesign expectations, recyclability and compostability standards, and long-term producer responsibility obligations.
CAWA’S perspective
SB 54 represents one of the most significant packaging regulations ever adopted in California and has the potential to affect a broad cross-section of the automotive aftermarket.
Manufacturers of lubricants, automotive fluids, replacement parts, chemicals, and accessories should not assume they are exempt simply because they operate outside the traditional consumer packaged goods sector.
Many companies may discover that the plastic containers used for motor oil, coolant, brake fluid, transmission fluid, fuel additives, and other automotive chemicals — as well as the packaging used for replacement parts — are covered under the law. In addition to potential reporting requirements, producers may ultimately be responsible for funding California’s packaging stewardship program and complying with increasingly stringent packaging performance standards.
CAWA will continue engaging with CalRecycle and other stakeholders throughout implementation and will keep members informed as additional guidance, reporting requirements, and compliance deadlines are announced.
We encourage members to evaluate their packaging now and remain actively engaged as this program continues to evolve.
Should you have any immediate questions or comments, contact CAWA’s Legislative Advocate in California, Ryan Pierini at 916-995-5323 or ryan@benchmarkadvocacy.com.
Comments are closed.