The industry knows what is coming.
It cannot yet price it.
The inaugural EPR Readiness Circle found a cohort that is engaged and increasingly informed — and not yet equipped to forecast what its at-risk formats will cost under SB 54.
On March 17, 2026, Circle by OPLN convened a cross-industry cohort of obligated producers, trade associations, consultancies, and producer responsibility organizations for its inaugural EPR Readiness Circle. Through anonymous pre-session polling and a structured ninety-minute discussion, one picture came through clearly: the industry is engaged, increasingly informed, and potentially under-equipped to accurately forecast the impact of at-risk formats under SB 54.
Flexible packaging is the industry's central vulnerability.
62%
name flexible formats as their highest exposure category
23%
point to fiber portfolios instead
15%
point to compostable plastics
Sixty-two percent of respondents identified flexible formats as their highest exposure category under SB 54 — nearly three times the share naming fiber. The concentration is the finding: this is not a portfolio spread across many worries, it is one category carrying most of the risk.
The factors driving that exposure are systemic rather than format-specific. Fee uncertainty and redesign timeline constraints lead at 55% each. Supplier limitations follow at 45%, alongside a tight cluster of infrastructure gaps — limited curbside acceptance, contamination during sorting, MRF screening loss, and weak end markets — each cited by 45% of participants. No single fix addresses a cluster like that.
Survey · Highest exposure category
Where Producers See the Most SB 54 Risk
Flexible formats carry nearly three times the exposure of fiber.
Survey · Risk drivers
Why Those Formats Are Risky
Fee uncertainty and redesign timelines lead. Four infrastructure gaps tie at 45%.
Financial modeling confidence remains low.
0%
report high confidence modeling eco-modulated fee exposure
54%
operate on rough assumptions only
15%
have no ability to model fee exposure at all
Zero percent of respondents reported high confidence in modeling eco-modulated fee exposure. The majority — 54% — operate on rough assumptions only, while 15% have no modeling ability at all. The distribution has no upper tail.
Discussion participants reinforced why. Fee schedules exist only for Colorado and Oregon, which leaves California's eco-modulation framework largely theoretical — producers are being asked to forecast against a price list that has not been published. The gap between the regulatory timeline and organizational readiness to quantify financial impact is significant, and it is widening.
Survey · Modeling capability
A Distribution With No Upper Tail
Share of respondents by ability to model eco-modulated fee exposure.
The remaining 31% sit between the two reported extremes: some modeling capability, but short of high confidence. No respondent reached it.
Supplier engagement has only just begun.
Thirty-eight percent of respondents are still assessing portfolio impact internally. Another 38% have initiated preliminary supplier conversations, and 23% have begun updating internal specifications. Then the pipeline stops: no respondent has communicated updated requirements to suppliers, and none has transitioned a format.
Survey · Supplier engagement stage
The Pipeline Is Almost Entirely Unfilled
Furthest stage reached, by share of respondents.
Assessing portfolio impact internally
Preliminary supplier conversations initiated
Internal specifications being updated
Updated requirements communicated to suppliers
No respondent has reached this stage
Formats transitioned
No respondent has reached this stage
Set that against the clock. Packaging redesign timelines are measured in years, and participants noted that some fresh-cut produce formats are an estimated fifteen years from viable alternatives. The disconnect between compliance deadlines and material reality is a structural tension the industry has not yet resolved — and it cannot be resolved on the producer's side of the table alone.
The biggest internal challenge is getting leadership to the table.
Sixty percent of respondents identified building executive-level buy-in as their top cross-team coordination priority — ahead of aligning packaging design with financial modeling (50%) and improving material data accuracy (50%). That ordering is worth sitting with. The practitioners closest to the work are not asking for more information. They are asking to be prioritized.
Survey · Cross-team priorities
What Practitioners Need Most Internally
Executive buy-in outranks both technical priorities.
The constraint this cohort reports is not knowledge or intent. It is organizational prioritization — and that is the one input a sustainability or packaging team cannot supply for itself.
For the executive desk
Implications for leadership.
The financial exposure from packaging EPR is real, imminent, and poorly quantified.
Not poorly quantified at one company — across the industry. No respondent in this cohort reported high confidence in the number they would have to defend.
Flexible packaging is a systemic risk, not a packaging problem.
It cuts across material science, recovery infrastructure, and regulatory design at once. Nothing in a single function's control resolves it.
The supplier engagement pipeline is almost entirely unfilled.
Internal assessment is underway; outbound requirements are not. Against redesign timelines measured in years, that ordering is the risk.
Practitioners are asking for what only senior leadership can provide.
Organizational priority, cross-functional authority, and investment in early-action piloting. The expertise is already in the building.