Your SB 54 Source Reduction Plan Is Filed
Will Your Plan Hold Up?
California’s packaging EPR law has moved from planning to implementation.
SB 54 regulations took effect May 1, 2026. Producers have registered, submitted baseline and supply data to Circular Action Alliance, and filed individual source reduction plans. Now, the first program milestone is approaching: a 10% reduction in plastic packaging by January 1, 2027.
For many companies, developing the plan was only the first step. The work now is determining how those commitments translate into packaging decisions that can meet California’s requirements while still making sense for the product, the business, and the recycling system.
A Familiar Strategy with New Stakes
Source reduction itself isn’t new. Elimination, lightweighting, right-sizing, material substitution, recycled content, reuse, and refill have been part of sustainable packaging strategies for decades. What SB 54 changes is the context in which those decisions are being made.
SB 54 sets escalating source reduction targets for plastic packaging, measured against a 2023 baseline: 10% by January 1, 2027, 20% by 2030, and 25% by 2032. The targets apply to Circular Action Alliance on behalf of its participating producers rather than to each company individually. But they are the benchmark every producer's individual source reduction plan is built around. Progress is measured by both plastic weight and number of plastic components. And recycled content counts, but is subject to a cap.
That makes source reduction more than a packaging design exercise. Companies need to understand not only whether a change reduces plastic, but how it counts toward their source reduction plan, what it costs, how it affects package performance, and what it means elsewhere in the packaging and recycling system.
Finding the Right Pathway
The question isn’t as simple as: How do we reduce plastic?
The question is: Which combination of strategies gives us a realistic path to compliance while balancing cost, performance, and system impacts?
No single source-reduction strategy works for every package or product. Each pathway comes with its own technical, operational, and economic considerations.
Elimination is often the most direct path. It removes plastic components that aren't doing essential work, like secondary wraps, redundant closures, or unnecessary windows. It reduces both weight and component count.
Right-sizing, lightweighting, and concentration trim material without removing the package: thinner walls, less headspace, concentrated formats. The tradeoff is how far you can go before shelf life, protection, or line performance suffers.
Shifting to non-plastic materials can move a package out of plastic entirely. But the alternative still has to protect the product and work within California's recycling system. A switch that looks good on a spreadsheet can create new problems in collection, sorting, or end markets.
Shifting to reusable or refillable packaging can deliver significant reductions, but only where the product, consumer behavior, infrastructure, and business model support it.
Recycled content plays a key role as it may also have implications to content mandates outside California. Post-consumer recycled content (PCR) counts toward source reduction but is capped at 8% of a producer's total requirement. Only increases above baseline levels count, and the PCR must be APR-certified. Companies still need to weigh availability, quality, cost, and whether maintaining performance requires more material.
Connecting Packaging Decisions to the System
Balancing compliance, cost, performance, and system impacts requires looking beyond the package itself.
RRS has worked for decades at the intersection of packaging, materials management, recycling infrastructure, markets, and policy. That systems perspective helps companies evaluate source reduction strategies based not only on what is technically allowed, but on how materials and packaging actually move through the system.
Our work spans sustainable packaging and material strategies and claims, material flow testing within MRFs, recyclability assessments, material sourcing and recycled content strategy, and guidance and compliance support for EPR and other packaging policies. That allows our team to connect decisions made upstream with what happens downstream.
RRS also works across the EPR ecosystem, including with producer responsibility organizations, government agencies, recyclers, producers, and other system stakeholders. That gives our team a view into both the policy requirements and the practical realities of implementation.
For companies implementing SB 54 source reduction plans, RRS can help:
• Stress-test existing plans to identify gaps, assumptions, and implementation challenges ahead of upcoming milestones.
• Compare source reduction pathways across compliance contribution, cost, package performance, EPR fee implications, and system impacts.
• Evaluate PCR strategies against real-world supply, quality, and end-market conditions.
• Assess material and packaging changes in the context of collection, sorting, processing, and recyclability.
• Build strategies across EPR programs and other packaging policies, such as recycled content mandates, so packaging decisions account for requirements beyond California.
From Plan to Implementation
Filing a source reduction plan establishes the pathway. The next challenge is making sure that pathway works.
Whether you’re pressure-testing an existing SB 54 plan, comparing source reduction options, or determining how individual packaging changes fit into a broader packaging compliance strategy, RRS can help connect the regulatory requirements to the technical and economic realities of implementation.
Attending SPC Advance this week?
Connect with the RRS Sustainable Packaging Guidance and Compliance Team to continue the conversation.
Anne Johnson
Principal & Vice President
Erika Le
Senior Consultant
Joel Schoening
Senior Consultant