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17 States and Wholesaler Group Sue to Block California's SB 54 EPR Law

Published
Score
23

Why it matters

On June 22, 2026, a coalition of 17 Republican-led states led by Nebraska, joined by the National Association of Wholesaler-Distributors, filed suit in the U.S. District Court for the Eastern District of California challenging California's Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54). The plaintiffs seek to block enforcement of the law, claiming it violates the Commerce Clause, the Import-Export Clause, the First Amendment, and federal due process protections by discriminating against out-of-state manufacturers and improperly delegating regulatory authority to a private entity. The defendants are CalRecycle Director Zoe Heller and the Circular Action Alliance, the producer responsibility organization selected to implement the statute. Critically, filing the lawsuit does not suspend SB 54 compliance obligations—producers must continue meeting registration, reporting, and implementation requirements unless a court orders otherwise.

The plaintiffs argue the statute constitutes an "unprecedented overreach" that harms producers, manufacturers, distributors, and consumers nationwide. SB 54 went into effect May 1, 2026, and shifted packaging management costs from local jurisdictions to producers through a mandatory Producer Responsibility Organization framework. The timing of this challenge is significant: environmental groups filed a separate lawsuit just three weeks earlier arguing the implementing regulations are too lenient and fail to align with the statute's intent. Meanwhile, similar constitutional challenges are already pending in Oregon and Colorado, where an Oregon court recently issued a preliminary injunction narrowly applying to NAW members.

Attorneys representing companies in the packaging supply chain should monitor this case closely. The lawsuit represents the first major interstate constitutional challenge to a state-level extended producer responsibility program since California's regulations took effect, and a ruling could have far-reaching consequences for similar EPR laws pending or proposed in other states. Producers face immediate pressure: key compliance deadlines are looming, including August 1 for Individual Source Reduction Plans, while courts actively debate the validity of the core statutory framework. Companies must continue compliance efforts while tracking the litigation's trajectory.

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