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What an Individual Source Reduction Plan is

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.

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

Individual plans are not binding, and the targets are met collectively through the PRO plan

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.

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 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.

MilestoneTotal plastic reductionMinimum via reuse or refill (2032: reuse, refill, or elimination)
January 1, 202710%2%
January 1, 203020%4%
January 1, 203225%, by weight and by component or unit count10%

The four recognized pathways

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

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.

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No approved formula exists yet. Under section 6.2.3.3 of the final draft program plan CAA submitted to CalRecycle on October 13, 2026, CAA would count toward the collective targets the APR-certified PCR producers report for the year, minus the APR-certified PCR reported for the 2023 baseline, up to 8 percentage points, and it would not apportion the credit to individual producers. The plan would also pay a separate bonus for APR-certified PCR (section 6.3.3.2) and is proposed until CalRecycle approves it. Until a formula is approved, do not count PCR toward the targets, but still report PCR use, since PRC 42057(d)(2)(E) requires the plan to state the amount of postconsumer recycled content used compared to virgin plastic.

Measurement and disclosure details

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.

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 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.

ISRP readiness checklist

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.

A. Scope and governance

  1. Confirm you are an obligated producer and identify your compliance path: CAA participant, independent producer with its own CalRecycle-approved plan (14 CCR 18980.7), or an approved small-producer exemption, which requires a formal application. Producers that are members of the PRO submit individual source reduction plans to it (PRC 42057(d)).
  2. Stand up a cross-functional team spanning research and development, procurement, packaging, legal, finance, marketing, and leadership. A plan forecasts portfolio changes across the business, so it cannot be written by a sustainability team alone.
  3. Note that the producer-level source reduction data CAA reports to CalRecycle is subject to the Public Records Act unless an exemption applies, designate any trade secrets as 14 CCR 18980.14 requires, and calibrate every claim accordingly.

B. Baseline

  1. Pull your 2023 plastic covered material sold or distributed into California. Every percentage in the plan measures against this figure.
  2. Record both weight and component or unit count, because every milestone is measured on both.
  3. Reconcile against the CY2023 baseline report already filed with CAA. An unexplained difference between your forward plan and the historical data CAA already holds can draw a query.

C. Pathway planning

  1. Map current packaging against the four pathways above. Do not count planned PCR increases as reduction; the alternative compliance credit is capped at 8 percent and has no approved formula behind it yet.
  2. Flag components that can be eliminated, and confirm what counts as a component before counting the reduction.
  3. Identify reuse and refill opportunities separately from lightweighting, so the floor can be evidenced later.

D. Targets and forecast

  1. Forecast net reduction against the 10, 20, and 25 percent milestones.
  2. Check the floors at each milestone: 2 and 4 percent through reuse or refill by 2027 and 2030, and 10 percent through reuse, refill, or elimination by 2032.
  3. Document methodology and assumptions for every estimated reduction. Forecasts may be estimates, but they have to be defensible and capable of refinement.

E. Submission

  1. Complete CAA registration and sign the Participant Producer Agreement, which gives access to the portal and the detailed reporting guidance.
  2. Enter and submit the plan in the CAA Producer Portal. CAA’s deadline for the first plans was August 3, 2026, so a producer that has not filed should contact CAA.
  3. Retain the submission and all supporting work for the compliance file. The plan is refined over time and you may need to show how a forecast was built.

How to build the forecast

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.

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 3, 2026 through the CAA Producer Portal. That is the effective deadline CAA set because August 1 fell on a Saturday. CalRecycle sets no ISRP deadline, says individual plans should not be submitted directly to it, and does not review them, so send yours to CAA and never to CalRecycle.
What is an Individual Source Reduction Plan?
A plan filed under California SB 54 that reports any source reduction since January 1, 2013 (first plan only, PRC 42057(d)(1)) and states how much plastic a producer plans to source reduce toward the statutory plastic reduction targets: 10% by 2027, 20% by 2030, and 25% by 2032, measured against a 2023 baseline, with minimum shares of 2% by 2027 and 4% by 2030 through reuse or refill (PRC 42057(a)(2)(C), (D)) and 10% by 2032 through reuse, refill, or eliminating a plastic component (42057(a)(2)(A)).
What counts toward SB 54 source reduction?
Four pathways: reuse and refill systems, elimination of unnecessary plastic components, switching to alternative non-plastic materials, and right-sizing or lightweighting or concentrating or shifting to bulk. Reuse and refill count toward every minimum share; elimination counts only toward the 2032 minimum of 10% (PRC 42057(a)(2)(A)). Post-consumer recycled content is not a fifth pathway: PRC 42041(aj) excludes switching from virgin material to PCR from the definition of source reduction. PRC 42057(a)(2)(B)(i) allows up to 8 percent to be met through an alternative compliance formula the PRO must develop and CalRecycle must approve, and no approved formula exists yet.
Is the 2032 SB 54 target measured by weight?
By weight and by component or unit count. A 25% reduction by weight alone, through lightweighting, does not meet the target, because PRC 42057(a)(1) also requires 25 percent by plastic component. Track component counts from the 2023 baseline forward.