SB 54 Compostable Material Standards: Labels, PFAS, Penalties

Under California’s SB 54, compostable material standards require that any single-use packaging or plastic food service ware labeled “compostable” meet a specific ASTM specification, carry certification from a CalRecycle-approved third party, contain no more than 100 parts per million of total organic fluorine, and — starting January 1, 2026 — qualify as an allowable input under the USDA National Organic Program. Getting it wrong exposes a producer to administrative civil penalties of up to $50,000 per day per violation.

What a Product Must Meet to Be Labeled Compostable

California Public Resources Code Section 42356 ties the word “compostable” to two ASTM specifications. ASTM D6400 applies to plastics designed for industrial composting. ASTM D6868 applies to paper and fiber products that incorporate plastic coatings or polymer additives, such as a lined coffee cup or a paper bowl with a moisture barrier.¹

Section 42357 adds the rest of the stack. Partial compliance with a section or subsection of the ASTM standard is not enough. As of January 1, 2026, a product labeled compostable must also qualify as an allowable agricultural organic input under the USDA National Organic Program. And the product’s total organic fluorine concentration cannot exceed 100 parts per million, a threshold designed to screen for PFAS contamination whether added intentionally or picked up during manufacturing.²

The ASTM standards themselves set performance thresholds that depend on physical form. ASTM D6400 tests whether a plastic disintegrates within roughly 84 days and fully biodegrades within 180 days under managed industrial composting conditions. Results are thickness-dependent, so a certification specifies the maximum thickness at which the product passed.³ ASTM D6868 confirms that any plastic coating on a paper substrate breaks down with the paper rather than leaving synthetic fragments behind.⁴

A product labeled “home compostable” has to meet an additional requirement: the manufacturer must hold OK Compost HOME certification from TÜV Austria, unless ASTM adopts a home-composting specification that CalRecycle determines is equally stringent.

Terms You Cannot Use on Plastic Products

Public Resources Code Section 42358 prohibits the use of “biodegradable,” “degradable,” or “decomposable” on plastic products sold in California.⁵ The words imply that a plastic will break down naturally in any environment, which is almost never true. Even plastics that fragment leave microplastic residue rather than returning to organic matter.

The practical consequence of these vague terms is contamination of the organics stream. When a shopper sees “biodegradable” and tosses the item into a green bin, composting facilities absorb the labor of pulling conventional plastic back out. The statute forces producers to either qualify for a true “compostable” label through ASTM certification or drop the environmental claim entirely.

Third-Party Certification

Since January 1, 2024, a manufacturer’s own lab data is not enough. Any product sold in California with a “compostable” label must be certified by a third-party entity approved by CalRecycle to confirm it meets the applicable ASTM specification.² The Biodegradable Products Institute and TÜV Austria are the best-known certifiers operating in this space.

Which ASTM standard applies depends on composition. Plastic products test against D6400. Paper and fiber products with polymer coatings or additives test against D6868. Producers must keep certification documentation on file and make it available to CalRecycle on request. A product sold without accurate supporting data can be pulled from sale statewide.

Industrial Versus Home Composting

The two certifications are not interchangeable. Industrial composting reaches thermophilic temperatures of 55 to 60 degrees Celsius, which accelerates microbial breakdown. Under EN 13432 and TÜV Austria’s OK Compost INDUSTRIAL certification, a material must reach 90 percent biodegradation within six months at those temperatures.

Home composting runs at ambient temperatures. OK Compost HOME certification uses the same 90 percent biodegradation threshold but allows 12 months to get there. A product certified only for industrial composting will not reliably break down in a backyard bin, which is why California treats “home compostable” as a separate claim with its own certification.

PFAS Limits on Compostable Items

Two California laws stack on this point. AB 1200, in effect since January 1, 2023, prohibits distributing or selling any food packaging in California that contains intentionally added PFAS.⁶ PRC Section 42357 goes further for compostable claims specifically, capping total organic fluorine at 100 parts per million regardless of whether the PFAS was added on purpose or arrived as trace manufacturing contamination.²

PFAS does not break down during composting. The EPA has documented that compost made from food-contact packaging containing PFAS carries higher concentrations than compost without such packaging, and that compost spread on farmland can transfer PFAS into groundwater or crops.⁷ The FDA has linked certain PFAS exposures to increased cholesterol, changes in liver function, decreased immune response, and increased risk of some cancers. As of early 2025, the FDA announced that all grease-proofing food contact substances containing PFAS have been voluntarily phased out by manufacturers in the U.S., though the California statutory bans remain in force as a backstop.⁸

Penalties for Noncompliance

CalRecycle can impose administrative civil penalties of up to $50,000 per day per violation against any entity that fails to comply with SB 54 or its implementing regulations. Smaller producers who meet certain criteria face a lower ceiling of $25,000 per day, as do first-time offenders whose violations are not considered egregious.⁹

Penalties do not start accruing until 30 calendar days after CalRecycle gives the entity notice of the violation. When setting the amount, CalRecycle weighs the severity and scope of the violation, whether the entity corrected the problem promptly, whether the conduct shows a pattern of noncompliance, whether the violation was intentional, and whether it was self-reported before an investigation began. The producer’s financial condition and the magnitude of harm to the environment, human health, and disadvantaged communities also feed into the calculation.⁹

CalRecycle also has the authority to reclassify materials. If a product technically meets ASTM D6400 in a lab but consistently ends up in landfills because no local facility accepts it, CalRecycle can tighten the requirements or strip the compostable classification, forcing the producer onto a different compliance pathway.¹⁰

Federal Labeling Rules Still Apply

California’s rules sit on top of the FTC’s Green Guides, which set a federal floor. Under the Green Guides, it is deceptive to claim a product is compostable unless the marketer has competent and reliable scientific evidence that it will break down into usable compost in a safe and timely manner, meaning at roughly the same rate as the organic materials it is composted with.¹¹

The FTC also requires qualifying language on a compostable claim when the product cannot be composted at home or when industrial composting facilities are not available to a substantial majority of consumers where the product is sold. That qualifier matters in California because composting infrastructure is unevenly distributed. A product sold statewide may be genuinely processable at an industrial facility in the Bay Area but have no option available in a rural Central Valley community. The Green Guides have not been updated since 2012, but the existing guidance remains in force.¹²

1
California Legislative Information. California Public Resources Code PRC 42356
2
California Legislative Information. California Public Resources Code PRC 42357
3
ASTM International. ASTM D6400-21 Standard Specification for Labeling of Plastics Designed to be Aerobically Composted in Municipal or Industrial Facilities
4
ASTM International. ASTM D6868 Standard Specification for Labeling of End Items that Incorporate Plastics and Polymers as Coatings or Additives with Paper and Other Substrates Designed to be Aerobically Composted in Municipal or Industrial Facilities
5
California Legislative Information. California Public Resources Code PRC 42358
6
California Legislative Information. California Health and Safety Code 109000
7
U.S. Environmental Protection Agency. Emerging Issues in Food Waste Management: Persistent Chemical Contaminants
8
U.S. Food and Drug Administration. Questions and Answers on PFAS in Food
9
California Legislative Information. California Public Resources Code PRC 42081
10
CalRecycle. Plastic Pollution Prevention and Packaging Producer Responsibility Act
11
Federal Trade Commission. Guides for the Use of Environmental Marketing Claims (Green Guides)
12
Federal Trade Commission. Environmentally Friendly Products: FTC’s Green Guides