California SB 54 vs. EU PPWR: New Packaging Compliance Requirements for International Brands
California and the European Union are strengthening their packaging regulations, introducing new requirements for recyclability, waste reduction, and Extended Producer Responsibility (EPR). California’s SB 54 and the EU Packaging and Packaging Waste Regulation (PPWR) represent two important regulatory frameworks for companies marketing products in both markets.
For cosmetics, personal care, food supplements, and other consumer goods brands, understanding these regulations is essential to ensuring that their packaging meets the applicable requirements in each market.
What is California’s SB 54 and where does it apply?
Senate Bill 54 (SB 54), officially known as the Plastic Pollution Prevention and Packaging Producer Responsibility Act, is a law enacted in California in 2022 to reduce packaging waste, improve recyclability, and establish an Extended Producer Responsibility system.
The legislation applies to certain single-use packaging and plastic food service ware sold or distributed in California, including packaging made from materials such as plastic, glass, metal, paper, and cardboard, subject to the exemptions established by law.
Although SB 54 is a state-level law, it may also affect international companies marketing their products in California through distributors, importers, or e-commerce platforms.
For example, a European cosmetics brand selling its products in California must determine whether its packaging falls within the scope of SB 54 and identify which entity qualifies as the responsible producer under the legislation.
Key SB 54 requirements: Targets for 2032
SB 54 establishes progressive targets for waste reduction and improved recyclability of the materials covered by the legislation.
By 2032, California aims to achieve three main objectives:
100% recyclability or compostability: Covered single-use packaging and plastic food service ware must be recyclable or eligible to be labelled as compostable.
25% reduction: Reduce the amount of covered single-use plastic materials compared with the established baseline.
65% recycling rate: Achieve this recycling rate for the single-use plastic materials covered by the legislation.
These targets apply to the programme and the relevant material categories. They should not be interpreted as identical individual recycling targets imposed on every company.
However, companies' obligations do not begin in 2032.
On 1 May 2026, the implementing regulations for SB 54 came into effect, establishing registration, reporting, and compliance procedures for affected producers.
Companies must determine whether they qualify as producers, identify their covered materials, verify their registration obligations, and assess their participation in the Extended Producer Responsibility programme managed by Circular Action Alliance (CAA), or the alternative compliance pathways provided by law.
SB 54 vs. EU PPWR: What are the main differences?
Regulation (EU) 2025/40, known as the PPWR, became generally applicable on 12 August 2026, although certain requirements are subject to later implementation dates.
Like SB 54, it aims to reduce packaging waste and promote a circular economy. However, the PPWR establishes a broader regulatory framework covering packaging design, composition, recyclability, labelling, and technical documentation.
Aspect | California SB 54 | EU PPWR |
Geographical scope | California, United States. | All 27 EU Member States. |
Scope of packaging | Single-use packaging and certain plastic food service ware. | Packaging made from all materials, subject to applicable exemptions. |
Recyclability | Covered packaging must be recyclable or eligible to be labelled as compostable by 2032. | Design-for-recycling requirements from 2030, or a later date depending on the relevant delegated acts, with additional requirements from 2035. |
Extended Producer Responsibility | State-level EPR programme. | National EPR systems in individual Member States. |
Documentation | Registration, material identification, and programme-specific reporting requirements. | Conformity assessment, technical documentation, and EU Declaration of Conformity, as applicable. |
An important distinction is that compliance with one regulatory framework does not automatically guarantee compliance with the other.
For example, packaging considered recyclable in California may not meet the European recyclability criteria established under the PPWR, and vice versa.
What does this mean for international brands?
A cosmetics brand marketing the same product in California and several EU Member States must assess its packaging against both regulatory frameworks.
This may involve reviewing material composition, assessing the recyclability of individual packaging components, and determining the applicable registration and Extended Producer Responsibility obligations in each market.
Using a single packaging design across multiple markets can facilitate international distribution, but it does not eliminate the need to verify the specific requirements of each jurisdiction.
For international companies, anticipating these obligations will help them plan the necessary packaging adaptations and develop a coordinated compliance strategy for the United States and Europe.
How can Belab Services help?
At Belab Services, we help international brands understand and manage the regulatory requirements applicable to their products and packaging.
Our team provides regulatory support for compliance with the EU PPWR and can help identify the relevant packaging requirements in international markets, supporting regulatory assessments and the planning of necessary adaptations.
Does your company market packaged products in Europe or the United States?
Contact our team to assess the regulatory requirements applicable to your products.
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