26 WESTERN PALLET
Advocacy in Action: California SB 54 Calls on Wood Packaging Recyclers
California’s landmark Senate Bill 54 (SB 54), also known as the Plastic Pollution Prevention and Packaging Producer Responsibility Act, is set to reshape the way packaging is produced, managed, and recycled in the state. Although it is often framed as a plastics-focused bill, its impact extends far beyond just polymers.
As CalRecycle develops the infrastructure to implement SB 54, it is calling on wood pack- aging recyclers in California to contribute critical data that will shape how wood materials are evaluated, recovered, and supported through new market development initiatives.
What Is SB 54?
Signed into law in June 2022, SB 54 establishes one of the most comprehensive extended producer responsibility (EPR) frameworks in the United States. The legislation mandates that all single-use packaging and plastic food service ware sold in California must be recyclable or compostable by 2032. Producers must reduce the amount of plastic packaging by 25%, ensure 65% of packaging is recycled, and contribute to a $5 billion fund over ten years to mitigate the impacts of plastic pollution.
But while much of the public attention has focused on plastics, the bill also applies to a broader category of “covered materials.” These include paper, metal, glass, and importantly, wood packaging. That includes pallets, crates, and wood boxes that are disposed of after consumer use.
The SB 54 Needs Assessment
To guide implementation of the bill, CalRecycle is conducting a Needs Assessment, an in-depth study examining California’s current collection, processing, and end-market capabilities for covered materials. This study is essential for de- termining where infrastructure investments and market development efforts are most needed.
Eunomia Research and Consulting, working on behalf of CalRecycle, is leading a key part of this assessment. As part of their work, they’ve issued a survey to gather input from post-consumer wood packaging recyclers, specifically those who process used wood packaging into wood chips or equivalent materials.
The goal is to understand:
What types and volumes of post-consumer wood packaging are currently processed
What challenges recyclers face (e.g., contamination, low yields)
What challenges recyclers face (e.g., contamination, low yields)
The state of end markets for processed wood (e.g., mulch, biomass energy, animal bedding)
What infrastructure or market support is needed to expand capacity
This information will directly inform how CalRecycle supports wood packaging through SB 54’s EPR framework.
Why Input from Wood Recyclers Matters
The Needs Assessment is a once-in-a-generation chance for recyclers and manufacturers to make their voices heard. SB 54’s language allows for differentiated treatment of materials based on recyclability, marketability, and contamination levels. In short, materials with strong recovery and end-market performance, like wood, have the opportunity to be recognized and supported, rather than grouped with more problematic packaging types.
That recognition matters. If wood packaging is demonstrated to be widely collected, processed, and used in end markets, it may be subject to less stringent producer fees or reporting burdens. Conversely, if data is lacking, wood could be inaccurately lumped in with other materials seen as hard to recycle or lacking viable end markets.
How to Participate
Eunomia and CalRecycle are urging companies that recycle post-consumer wood packaging—including pallets, crates, and wood boxes—to fill out a short survey by June 10, 2025. The survey takes 15–30 minutes and can be found here:
🔗 SB 54 Wood Recycling Survey
Companies that prefer to discuss the questions over the phone can also schedule a walk-through with the consulting team. Participation is confidential and will be used only to support the assessment process.
If your company handles post-consumer wood packaging in California, now is the time to get involved. Sharing your expertise helps ensure that wood is properly represented in the state’s recycling roadmap—and strengthens the case for investments that can make the industry even more resilient in the years ahead.
For questions or assistance with the survey, companies can reach out directly to Eunomia Research and Consulting, or contact CalRecycle through the channels listed in the outreach letter.
Double-click to add text