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title: California SB 54 and the New Labeling Law: Packaging Decisions in a Minefield
lang: en
source: https://mindsprt.dev/en/knowledge/california-epr-source-reduction-deep-dive/
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# California SB 54 and the New Labeling Law: Packaging Decisions in a Minefield

*Industry Insights · 4 min read · 2026-10-10*

> California's SB 54 EPR fight meets SB 343's recycling-labeling requirements, leaving brands to review packaging structure, sourcing costs, and environmental commitments at the same time. This article breaks down how the two laws overlap from an export perspective and lays out checks to run before revising artwork

**Quick answer:** California SB 54 pushes packaging responsibility back through the brand supply chain, while SB 343 concerns the basis for recycling claims. MINDS (MS) recommends checking the market, packaging structure, and supporting evidence before approving artwork

## What do California SB 54 and SB 343 cover?

California Senate Bill 54 (SB 54, the Packaging EPR Law) concerns producer responsibility for packaging and source reduction. Senate Bill 343 (SB 343, the Recycling Labeling Law) concerns whether recycling claims on packaging can be substantiated. Extended producer responsibility (EPR) shifts responsibility for recycling and disposal after a product is sold back to the producer, prompting brands to account for what happens to packaging at the design and sourcing stages. Source reduction means cutting the amount of packaging that will become waste by addressing its volume, structure, and materials in advance.

I look at the two laws separately: one asks companies to address the responsibility that comes with packaging, while the other examines what the packaging claims. The structure and labeling on the same package each need to stand on their own. Don't lump them together as a single "eco-label" issue.

## Why does packaging design affect brand costs?

Packaging design affects brand costs because source reduction takes work across the brand, manufacturer, and materials supply chain. Changing the layers or materials in composite packaging means rechecking barrier performance, sealing, abrasion resistance, and print adhesion. Consumers see the package, but the brand bears the gap between how it performs in use and its environmental claims.

Paper-based materials aren't automatically recyclable either. Films, coatings, windows, and adhesives can all affect how recycling facilities process a package. My recommendation is to start by listing the SKUs sold in California, ask material suppliers for specifications and supporting documentation, then estimate revision costs against actual packaging needs. Before switching everything over, get a clear picture of which orders and production steps each change will affect.

## Does an industry lawsuit mean SB 54 is on hold?

An industry lawsuit doesn't mean SB 54 is no longer in effect. The American Forest & Paper Association (AF&PA) and the Flexible Packaging Association (FPA) argue that SB 54 violates free speech. That is an industry group's legal argument, not a court ruling, and it doesn't mean the law has been suspended. [Packaging Dive's report](https://www.packagingdive.com/news/california-league-food-producers-lawsuit-sb343-sb54/832581/) covers the dispute.

For brands, the lawsuit hasn't answered the immediate artwork question. If the front of a package says "recyclable," the purchasing records, material specifications, and basis for the claim should all line up. A lawsuit doesn't supply evidence for packaging already in use. Before exporting a product, brands still need to check whether the rules in effect apply to their product in the target market.

## How should brands plan a packaging audit?

Before the next packaging proofing round, brands should review the SKUs exported to California, their packaging structures, and the versions of their labeling. These are internal print approval checkpoints, not legal deadlines.

・List the products sold in California, their packaging versions, and the brand or client contact responsible for approval

・Ask material suppliers for specifications for each layer, coating, and adhesive, and keep dated copies of each document version

・Check each "recyclable" claim and symbol against the actual packaging, and confirm that the supporting basis applies in the target market

・Have the brand's compliance or legal contact approve the packaging structure and claims before proofing. If the materials or copy change, send them back for review

Start with the market. If one package is supplied to multiple regions, first sort out each region's customer requirements and approved versions, then decide whether you can use the same artwork across them.

## Where can printers and SaaS teams help brands keep things in check?

Printers can keep material versions, artwork, and approval records aligned. A SaaS system can keep the SKU, material specifications, label copy, target market, and document versions together in one record. This can prevent delivery problems such as using the wrong artwork or failing to record a material substitution, but it can't replace the brand's judgment on whether a law applies.

When designers hand over artwork, they should link the label copy to its approval basis. If a printer changes materials or revises artwork, the brand should review it again. Printers shouldn't carry over an old claim on their own. If a brand lacks a packaging compliance contact, the [Mai Strategy Knowledge Academy consulting team](https://mindsprt.dev) can help organize packaging information and the print approval process. Start with one export product line.

## Key takeaways

・SB 54 covers packaging responsibility, while SB 343 covers recycling labels. Brands should check them separately

・Paper-based packaging isn't automatically recyclable. Check the structure, coatings, and attachments

・A legal argument in a lawsuit isn't a court ruling. Check the target market's rules before exporting

・Before proofing, align material documentation, the basis for labeling claims, and the approved artwork version

## Further thoughts

As a next step, brands can gather their export SKUs, packaging specifications, label artwork, and supplier documents in one place, then run them through the approval process on the next packaging revision. Print production and design teams need to record material substitutions and artwork changes. AI or SaaS tools can help compare fields and flag missing documents or version differences, while the brand contact remains responsible for the legal judgment.

## Further reading

・[A double hit from California's new EPR and labeling laws: A closer look at the compliance minefield for brands, printers, and packaging designers](https://www.packagingdive.com/news/california-league-food-producers-lawsuit-sb343-sb54/832581/)

## FAQ

### What's the difference between California SB 54 and SB 343?

SB 54 concerns producer responsibility for packaging and source reduction. SB 343 concerns recycling claims on packaging. Brands should review packaging responsibility and the basis for labeling claims separately.

### Can a paperboard box or paper-based package be labeled recyclable as is?

You can't decide based only on whether the main material is paper. Films, coatings, windows, and adhesives can all affect how a package is processed for recycling. Before labeling it, check the actual structure and the requirements in the target market.

### Can brands hold off after industry groups sue over SB 54?

Don't treat an industry group's legal argument as a court ruling or as proof that the law has been suspended. Before exporting, check the rules currently in effect in the target market and whether they apply to your product.

### Are printers responsible for deciding whether packaging complies with California law?

Printers should produce packaging using the materials and artwork approved by the brand, and notify the brand for review if materials or versions change. The brand's compliance or legal contact should make the legal judgment on packaging claims.


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