The Circular Action Alliance (CAA) is the nonprofit Producer Responsibility Organization (PRO) responsible for implementing the circular economy for paper and packaging EPR in California. Their role includes helping producers meet their statutory goals, facilitating compliance, collecting fees, and investing in the state's recycling infrastructure and education.

The law sets three major targets to be achieved by 2032:

• 25% reduction in single-use plastic packaging (10% of which must come from reuse, refill, or elimination).

• 65% recycling rate for all single-use plastic packaging.

• 100% recyclability or compostability for all covered packaging. Note that while the first two are industry-wide obligations managed by the PRO, the 100% recyclable/compostable target is an individual producer obligation.

Currently, there are no de minimis exclusions. Producers are required to report components like labels, inks, and adhesives as part of the total weight of the packaging. CAA intends to apply for de minimis determinations (e.g., for cold end coatings on glass) once regulations are effective, but these will not be finalized before the initial reporting deadlines.

Data must be prepared across 95 different covered material categories, requiring very detailed component-level reporting.

These plans are required for plastic producers to outline how they intend to meet reduction targets. They track methods such as reuse, refill, right-sizing, or "alternative compliance" through Post-Consumer Recycled (PCR) content. Up to 8 points of the reduction targets can be met through PCR usage.

Statutory penalties can reach up to $50,000 per day for non-compliance. Furthermore, CAA is required in some states to escalate the names of non-participating producers to the regulator to ensure system fairness. Late-comers will also be required to back-report and back-pay for missed program years.