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 five pathways that count, and the two things producers most often get wrong.
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Facts on this page were last verified against primary sources on July 26, 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; the reporting fields sit behind portal registration and the Participant Producer Agreement.
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 five 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.
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. A free ISRP prep checklist is available on the California guide.
Sources: California SB 54 (Allen, Ch. 75, Statutes of 2022), Pub. Res. Code 42057; 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.