California SB 54: What Indiana Manufacturers Need to Know Before July 13

On June 22nd, a 17-state coalition, including Indiana AG Todd Rokita, filed a federal lawsuit in the Eastern District of California targeting SB 54, California's packaging producer responsibility law. The lead plaintiff is the National Association of Wholesaler-Distributors, and the core legal challenge targets the Circular Action Alliance fee dispute structure, which routes disagreements to binding arbitration administered by CAA itself, no court access.

What most operators are missing: this is not a plastics-only issue. The CAA fee regime covers glass, aluminum, paper, and cardboard. If you ship any of those materials into California, directly or through a brand owner, you have potential fee exposure. The program budget could reach $1.87 billion in 2027 alone and $17.2 billion over five years.

A federal judge in Oregon already granted NAW a preliminary injunction in February, flagging the arbitration structure as raising serious constitutional questions. That injunction only protects NAW members. Non-NAW Indiana manufacturers are outside that protection, with CAA registration obligations live now and fee assessments scheduled to begin as early as January 2027.

The five-day merits trial in the parallel Oregon case starts July 13th. A plaintiff win there is the single most important near-term indicator for whether CAA fees arrive in January 2027 or get blocked first. If you ship packaging into California and you're not an NAW member, confirm your registration status before that trial concludes.