Circular Action Alliance (CAA) evaluates the submitted Individual Source Reduction (ISR) Plans to draft its strategy to achieve the mandatory plastic source reduction benchmarks laid out in California’s SB 54. For example, information about producers’ anticipated source reduction methods and quantities may inform CAA’s fee incentives for source reduction or the areas in which CAA invests in building reuse/refill systems. 

The ISR is not a binding commitment by a producer, so a producer will not violate SB 54 or their participation with CAA simply by failing to achieve the goals in its ISR. Producers are, however, required to (1) report their plastic source reduction data annually to CAA and (2) pay applicable fees to CAA. For example, CAA may incentivize producer behavior by charging higher fees for plastic covered materials. 

Producers should continue to track their plastic covered material component-level data, evaluate source reduction opportunities, and monitor CAA’s reporting requirements and fee schedule to remain in compliance with SB 54 and CAA. 

We can help your team understand what’s required, what’s optional, and what informs your strategic compliance under California’s current EPR scheme.