Producers of plastic covered packaging file an Individual Source Reduction Plan with the Circular Action Alliance forecasting how they will hit SB 54 reduction targets against a 2023 baseline. This page covers what the plan contains, the targets, the four pathways that count, why post-consumer recycled content is not one of them, and the two things producers most often get wrong.
Free. Updated weekly. No login required.
Facts on this page were last verified against primary sources on August 10, 2026. The EPR Atlas is re-checked weekly; this stamp moves only when a verification pass actually runs, not when the site rebuilds.
Under California SB 54, producers of plastic covered packaging file an Individual Source Reduction Plan, or ISRP, with the Circular Action Alliance through its Producer Portal. The plan is a forward-looking forecast: it describes how you intend to reach the statute's plastic reduction targets, measured against your own 2023 baseline. It is not a report of what you have already done.
The filing deadline has been communicated as August 1, 2026. CAA may adjust that date as rulemaking settles, so confirm the current date in the portal rather than relying on any secondary source, including this one. There is no public fill-in template, but CAA published Individual Source Reduction Plan Guidance in March 2026, available to registered producers in the CAA Producer Portal, where the reporting fields also sit.
Reduction is measured against your 2023 baseline of plastic covered material. Each milestone carries a total reduction figure and a floor for how much of it must come from reuse, refill or outright elimination rather than from other pathways.
| Milestone | Total plastic reduction | Minimum via reuse, refill or elimination |
|---|---|---|
| January 1, 2027 | 10% | 2% |
| January 1, 2030 | 20% | 4% |
| January 1, 2032 | 25%, by weight and by component or unit count | 10% |
SB 54 recognizes four routes to reduction, and they are not equally weighted. The first two carry the minimum shares in the table above, so a plan built only on the others will not satisfy the statute. A fifth item is commonly listed alongside them and does not belong there: post-consumer recycled content is excluded from the statutory definition of source reduction and reaches the target by a separate, capped route. It is set out below because a plan built on it will not do what its author expects.
Post-consumer recycled content is a capped alternative compliance credit, not a fifth pathway. PRC 42041(aj) states that source reduction “does not include ... switching from virgin covered material to postconsumer recycled content.” PRC 42057(a)(2)(B)(i) then allows no more than 8 percent of plastic covered material to be source reduced through an alternative compliance formula developed by the PRO and subject to approval by CalRecycle, on a sliding scale based on the ratio of virgin plastic to postconsumer recycled content. The credit is available only where the PCR content is validated by an approved third party, such as the APR Postconsumer Resin Certification Program, and does not contain intentionally added PFAS.
The 2032 target is measured two ways. Twenty-five percent by weight and by component or unit count. A program that lightweights aggressively can hit the weight target and miss the count target entirely. Instrument both from the first baseline, because reconstructing component counts retroactively is painful.
A filed ISRP can be subject to public records requests. Write every claim so it survives being read by a regulator, a competitor or a journalist. Forecasts that cannot be substantiated later are a liability, not a placeholder.
Start from the 2023 baseline, because everything is measured against it. You need plastic covered material sold into California in 2023 by weight and by component count, split in a way that lets you show movement by pathway. Then map each planned change to a pathway, quantify it, and check that the reuse, refill and elimination share clears the floor at each milestone.
The design side of this overlaps almost completely with fee reduction, since the same material decisions drive both. Model the fee consequence of a proposed change in the EPR fee calculator before committing to it in a plan, and check the recyclability consequence in the Design for Recyclability Rater. Broader orientation across all seven states is on the Prepare for EPR page.
Fifteen items in the order they are usually best worked. Assign an owner and a target date to each. This is preparation, not the filing; the filing itself happens in CAA's portal, and there is no public template to fill in beforehand; CAA's own Individual Source Reduction Plan Guidance is available there once you are registered.
The arithmetic is straightforward once the inputs exist. Start from 2023 plastic covered material by category, in pounds and in component count. Log each planned action against a pathway, the products and components it affects, the target program year, the estimated plastic weight reduced, and whether it counts toward the reuse floor. Sum the planned reductions and compare them against the required percentage of baseline at each milestone. Where the total falls short, the gap is what the plan has to explain.
Two disciplines separate a plan that survives scrutiny from one that does not. Record the assumption behind every estimate, for example the volume share you expect to shift to a refillable format in year one, because an unexplained number cannot be defended or refined later. And keep the reuse, refill and elimination subtotal visible at every milestone rather than only the headline percentage.
If the plan is due and the forecast does not reach the milestones, that gap is worth working through properly rather than filing around. Advisory support on source reduction planning and portfolio analysis is available at info@hartteradvisory.com.
Sources: California SB 54 (Allen, Ch. 75, Statutes of 2022), Pub. Res. Code 42041(aj) and 42057(a)(2)(B)(i); CAA California Program Plan filed June 15, 2026, section 6.2.3.3; Circular Action Alliance California producer guidance. Reduction targets confirmed by statute; deadline and filing mechanics signaled per CAA guidance.
Every state guide carries the full fee schedule, registration deadlines, program plan status, eco-modulation detail, statute and rule text, and exemptions.