Producers of plastic covered packaging that participate in CAA file an Individual Source Reduction Plan with the Circular Action Alliance forecasting how much plastic they plan to source reduce toward SB 54's collective targets, measured 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 two details of measurement and disclosure.
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Last updated October 25, 2026.
Under California SB 54, producers of plastic covered packaging that participate in CAA file an Individual Source Reduction Plan, or ISRP, with the Circular Action Alliance through its Producer Portal. The plan is mainly a forecast of how much plastic you plan to source reduce by 2027, 2030, and 2032 toward the statute's targets, measured against your own 2023 baseline, and the first plan also reports any source reduction achieved since January 1, 2013 (PRC 42057(d)(1)).
The filing deadline was August 3, 2026, the effective date CAA set because the August 1 date fell on a Saturday. CalRecycle's Source Reduction Reporting Guidance of August 4, 2026 states that producers submit individual plans to the PRO according to the PRO's guidance, that plans should not be submitted directly to CalRecycle, and that CalRecycle will not review them, so CAA's date governs. Send your ISRP to CAA, never to CalRecycle. 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, which also holds the reporting fields.
CalRecycle’s Source Reduction Reporting Guidance states that producers submit individual plans to the PRO according to the PRO’s guidance, and that “these individual plans will inform the collective source reduction plan prepared by the PRO and are not binding commitments on behalf of producers.” CalRecycle reviews the PRO plan and does not review individual plans.
The targets work the same way. The guidance states that the source reduction targets for plastic covered material “are a collective responsibility that must be achieved through the PRO plan, rather than requirements applied uniformly to individual producers or uniformly to each covered material category”, and that all participant producers reach compliance “so long as the collective reductions realized through the PRO plan meet or exceed the target amounts”.
You are not individually required to reach a 10 percent reduction by 2027, and a plan that forecasts less than the headline figure is not by itself a violation. What you are required to do is file the plan with CAA on time, report annual data on plastic covered material to the PRO, and contribute to implementing the approved PRO plan under the enforceable agreement PRC 42057(a)(1) requires the PRO to hold with each participant. Because compliance is measured on the aggregate, the allocation happens in the PRO plan, and in that process CAA submitted the final draft PRO plan to CalRecycle on October 13, 2026, for approval on or before January 1, 2027.
Source: CalRecycle, SB 54 Source Reduction Reporting Guidance, published August 4, 2026 (updating the version published July 17, 2026). Evidence label confirmed.
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 particular pathways: the 2027 and 2030 floors must come from shifting to reusable or refillable packaging (PRC 42057(a)(2)(C), (D)), and the 2032 floor from reuse, refill, or eliminating a plastic component (42057(a)(2)(A)). CAA's plan Table 1 groups all three milestones as reuse, refill, and elimination.
| Milestone | Total plastic reduction | Minimum via reuse or refill (2032: 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, which the PRO must meet across all participant producers, so reductions through the other two pathways do not count toward those floors. Post-consumer recycled content is excluded from the statutory definition of source reduction and reaches the target by a separate, capped route, set out below.
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.
CalRecycle's guidance and CAA's plan measure every milestone two ways, by weight and by plastic component count, so the 2032 target is 25 percent on both. 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 goes to CAA, which is not required to submit it to CalRecycle, but the data drawn from it reaches CalRecycle. CAA must treat information producers give it as confidential (PRC 42052(e)), and CalRecycle says ISRPs should not be submitted to it directly. The producer-level source reduction data CAA reports in its plans and annual reports (PRC 42057(c)) is subject to the Public Records Act unless an exemption applies, and trade secrets are withheld only if designated as 14 CCR 18980.14 requires. Write every claim so it survives being read by a regulator, a competitor, or a journalist.
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 qualifying share clears the floor at each milestone: reuse or refill for 2027 and 2030, reuse, refill, or elimination for 2032.
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.
Work the items below roughly in order, and assign an owner and a target date to each. The filing itself happens in CAA's portal, where CAA's Individual Source Reduction Plan Guidance is available once you are registered.
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.
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 and refill subtotal, and for 2032 the elimination subtotal, visible at every milestone alongside the headline percentage.
Where the forecast does not reach the milestones, 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, final draft submitted to CalRecycle October 13, 2026, sections 6.2.3.3 and 6.3.3.2; Circular Action Alliance California producer guidance. Reduction targets confirmed by statute; deadline and filing mechanics signaled per CAA guidance.
Every state guide has the fee schedule where one has been published, registration deadlines, program plan status, eco-modulation detail, the statute and any implementing rule, and exemptions.