What an Individual Source Reduction Plan is

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.

The deadline and filing mechanics are signaled per CAA guidance rather than fixed in regulation. The reduction targets below are confirmed in statute.

The targets you are planning against

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.

MilestoneTotal plastic reductionMinimum via reuse, refill or elimination
January 1, 202710%2%
January 1, 203020%4%
January 1, 203225%, by weight and by component or unit count10%

The five recognized pathways

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.

Two details producers miss

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.

How to prepare

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.

Frequently asked questions

When is the California source reduction plan due?
Producers of plastic covered packaging have been directed to file an Individual Source Reduction Plan with the Circular Action Alliance by August 1, 2026 through the CAA Producer Portal. CAA may adjust the date as rulemaking settles, so confirm the current deadline in the portal.
What is an Individual Source Reduction Plan?
A forward-looking plan filed under California SB 54 describing how a producer will meet the statutory plastic reduction targets: 10% by 2027, 20% by 2030 and 25% by 2032, measured against a 2023 baseline, with minimum reuse, refill or elimination shares of 2%, 4% and 10% respectively.
What counts toward SB 54 source reduction?
Five pathways: reuse and refill systems, elimination of unnecessary plastic components, switching to alternative non-plastic materials, right-sizing or lightweighting or concentrating or shifting to bulk, and post-consumer recycled content as an alternative route. Only the first two count toward the minimum reuse, refill or elimination share.
Is the 2032 SB 54 target measured by weight?
By weight and by component or unit count. Both. A producer that meets the 25% reduction on weight alone through lightweighting has not met the target. Track component counts from the 2023 baseline forward.