Do I owe EPR fees California

Check your own case

Choose your role, add your revenue and the packaging you supply, and the checker applies the rules this page describes to your figures. It runs in your browser and stores nothing.

The Instica free plan covers the threshold check, exemption tracking, the deadline calendar, packaging templates and fee sources, so you can start without paying. See what the free plan includes

How the checker reaches a result

The checker asks the same questions in the same order for every place, and it stops with a result as soon as a question settles the matter. It never fills a missing answer in for you.

1. Whose brand is on the packaging? If it is another company's brand, you are not the producer for those goods under the roles recorded for California. If you have not said, the checker asks first.
2. Do you sell into California? A place where you report no sales returns not obligated.
3. Does a size limit apply? The checker compares your revenue or packaging weight with each limit on record and, where a limit is not met, returns below threshold.
4. Is an exemption on record for your case? An exemption that is not yet verified is never assumed, and the checker asks for more data instead.
5. Are related companies counted together? Where the rules add up affiliated companies, their figures are combined before the limits are compared.

Who is the producer in California?

The first question is whose duty it is. California assigns the duty by packaging level, and the table shows which roles count as the producer at each level.

• California: for other packaging the producer is the manufacturer or brand owner, licensee, or first distributor.
• California: for primary (sales) packaging the producer is the manufacturer or brand owner, licensee, or first distributor.
• California: for secondary packaging the producer is the manufacturer or brand owner, licensee, or first distributor.
• California: for service packaging the producer is the manufacturer or brand owner, licensee, or first distributor.
• California: for shipping packaging the producer is the manufacturer or brand owner, licensee, or first distributor.
• California: for tertiary (transport) packaging the producer is the manufacturer or brand owner, licensee, or first distributor.

Find the row that describes you. Where more than one role appears in a row, the checker asks whose brand is on the product before it gives a result.

Does revenue matter in California?

Where a revenue limit applies, California counts revenue earned in the jurisdiction. The revenue figure is taken over the calendar year. Limits are stated in USD; a figure in another currency is converted with a published rate before it is compared.

Size limits in California

Some rules switch the duty on or off by size. These are the limits on record for California, each with what happens when you meet it.

The revenue limit: $1,000,000

California: the revenue limit is $1,000,000. California: at the revenue limit of $1,000,000, the producer is exempt below it. California: the revenue limit of $1,000,000 applies to figures below it. California: the revenue limit is counted as follows: gross annual sales in California, most recent calendar year.

Exemptions in California

An exemption removes the duty for a producer that meets its conditions. Some must be applied for; others apply on their own.

Exemption 1

Exemption 1: Temporary, renewable exemption from most reporting and fee requirements for producers with gross annual California sales under $1 million. Long-term duty remains: all packaging recyclable or compostable by 2032. California: exemption 1 must be applied for. California: the application window for exemption 1 is: Register in PEPRS as a Packaging EPR producer, then file the small producer exemption application. California: exemption 1 is renewed as follows: renewable (interval not stated on the page).

Exemption 2

Exemption 2: A person who produces, harvests and packages an agricultural commodity on the site where it was grown or raised is not a producer. California: exemption 2 applies without an application.

Exemption 3

Exemption 3: Beverage containers subject to the California Beverage Container Recycling and Litter Reduction Act are not covered material. California: exemption 3 applies without an application.

Exemption 4

Exemption 4: Covered material meeting a 65% (through 2026) or 70% (2027 on) recycling rate, outside curbside collection and commingled sorting, recycled at responsible end markets, is not covered material once CalRecycle approves the producer's demonstration. California: exemption 4 must be applied for. California: the application window for exemption 4 is: annual demonstration to CalRecycle until 2027, every two years after. California: exemption 4 is renewed as follows: see description.

What the rules cover in California

A duty applies only to the packaging and the sales channels that the rules cover. This is what is on record for California.

California: a producer may not pass the duty to another party.

Every case, worked through

Below, the same engine that powers the checker is run on a set of standard cases for California. Each case states the input, the result and the next step. The figures are test inputs set at half, equal to and twice each recorded limit, read as of September 29, 2026; they are not rules.

Revenue of $500,000: below the limit

Your own brand is on the goods and your revenue is $500,000, half the limit of $1,000,000. The figure is under the $1,000,000 limit, so the engine returns below threshold: the exemption on record applies. Result: below threshold. Next: keep the figures that put you below the limit, and check again as you grow.

Revenue of $1,000,000: exactly at the limit

Your own brand is on the goods and your revenue is $1,000,000, exactly the limit of $1,000,000. The limit is met, so the engine returns obligated. Result: obligated. Next: register, report and pay as the sections below describe, and prepare your figures in a workspace.

Revenue of $2,000,000: above the limit

Your own brand is on the goods and your revenue is $2,000,000, twice the limit of $1,000,000. The limit is met, so the engine returns obligated. Result: obligated. Next: register, report and pay as the sections below describe, and prepare your figures in a workspace.

Above every limit

Your own brand is on the goods and every figure is above every limit on record. The limit is met, so the engine returns obligated. Result: obligated. Next: register, report and pay as the sections below describe, and prepare your figures in a workspace.

If you owe: what happens next

If the result is obligated, these are the steps on record for California. You register, report and pay yourself; Instica prepares the figures and the files.

California: registration is made with PEPRS (CalRecycle Packaging Extended Producer Responsibility System). California: registration is made by this party: The producer, or Circular Action Alliance on behalf of participants.

California: producers meet the duty through a single producer responsibility organisation. California: the organisations on record are Circular Action Alliance. California: membership of an organisation is required. California: an authorised representative is not required.

Deadlines on record

• California: the registration deadline is January 1, 2027.
• California: the material-category update deadline is January 1, 2027.