Audit, Compliance and Risk Blog

In September 2025, California extended and amended authority for its statewide greenhouse gas (GHG) “cap and trade” program through 2045 – and rebranded it as “cap and invest.” The California Air Resources Board (ARB) has administered this program since 2012, as part of broader GHG reduction provisions created by 2006’s Assembly Bill (AB) 32. AB 32 initially committed the state to reduce total GHG emissions back to 1990 levels by 2020 (achieved in 2018); ARB’s latest GHG reduction scoping plan (issued in 2022), seeks to reduce statewide emissions to 85% below 1990 levels by 2045, achieving carbon neutrality. Subsequent legislation extended implementing authority for cap-and-trade and other related programs available to the California Air Resources Board (ARB) and other agencies through 2030. (I wrote about that extension (AB 398) HERE ).  The newest legislation (AB 2017 and Senate Bill (SB) 840) continues the state’s GHG reduction efforts by making further changes to ARB’s cap and trade authority. The rest of this note summarizes these changes.

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The California Department of Resources Recycling and Recovery (CalRecycle) has published a revised set of proposed regulations to implement 2022’s Senate Bill (SB) 54, the “Plastic Pollution Prevention and Packaging Producer Responsibility Act.” (I wrote about the legislation HERE). The Act phases in a ban on non-recyclable single-use plastics by 2032, and requires that threshold proportions of single-use items sold as “recyclable” will actually be recycled. Its implementation will make use of “extended producer responsibility” (EPR) mechanism similar to those used in California and elsewhere for other enhanced recycling programs (I’ve written about these before, most recently HERE). The remainder of this note discusses the proposed regulations and SB 54’s provisions. 

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