California Source Reduction - Making Sense of Requirements and Timelines

One of the more unique, controversial, and misunderstood aspects of California’s extended producer responsibility (EPR) packaging program (SB 54) is its source reduction requirements.  Over the last few months, California’s producer responsibility organization (PRO), the Circular Action Alliance (CAA), has sponsored workshops open to the public and published guidance for registered producers that alleviate some of the confusion in advance of CAA’s May 31, 2026, deadline for producers to submit their first Annual Source Reduction (ASR) Reports.  This article provides a general overview of the source reduction requirements.[1]

Source Reduction Basics

Source reduction is the decrease in the amount of a producer’s covered material relative to the baseline through methods approved by SB 54, including concentration, right-sizing, lightweighting, eliminating plastic components, and shifting to reusable or refillable packaging. Under SB 54, the PRO must achieve a 25-percent reduction, by weight and by plastic component, of plastic covered material by January 1, 2032, relative to the 2023 baseline. CAA, as the approved PRO, is responsible for meeting this target at the program level and largely relies on producer-reported data to track progress.  To meet their own statutory obligations, CAA, in turn, has imposed certain requirements on producers, including timelines for submission of reports.

Baseline Reporting and Regulatory Timing

CalRecycle’s recently resubmitted SB 54 regulations are expected to be adopted no later than May 1, 2026, initiating a 30-day clock for producers to submit annual reporting and 2023 baseline data to CAA no later than June 1, 2026. Click here for Regulations Submitted to OAL for Approval, EPR Group Blog, March 23, 2026.

According to CAA, in some circumstances, previously submitted 2023 baseline data reports may also need to be amended and resubmitted by May 31, 2026.

2025 Reporting and Multi-State Harmonization

CAA has established a May 31, 2026, deadline for annual/initial supply data reporting across California, Oregon, Colorado, Maryland, Minnesota, and Washington. In California, this deadline also includes submission of the ASR Report for 2025 data. Many Canadian provinces also have May 31 reporting deadlines. Thus, harmonized reporting schedules will also contribute to compressed, multi-jurisdictional reporting timelines.

Annual Source Reduction Reports[2]  

ASR Reports will be a recurring component of California reporting for all producers focused on achieved source reduction. Each year, producers are expected to report prior-year supply data, including plastic weight and components, total source reduction relative to 2023, and achieved reductions by pathway (e.g., via rightsizing, material substitution, reuse/refill). Additional reporting guidance is expected in a forthcoming addendum, which will be available to registered producers on CAA’s website.

Individual Source Reduction Plans

Individual Source Reduction (ISR) Plans are one-time submissions that CAA has indicated will be due in summer 2026. They forecast a producer’s anticipated net source reduction and detail how a producer intends to achieve it via one or more source reduction pathways. Registered producers may download a recently released workbook that CAA developed to help producers prepare data for ISR Plans.

ISR Plans require detailed historical and forward-looking data, supported by extensive inputs such as historical net source reduction data (2013–2022), Association of Plastic Recyclers-certified post-consumer recycled (PCR) plastic usage in 2023, and projected supply and reduction metrics, along with accompanying qualitative explanations. CAA will aggregate ISR Plan data for submission to CalRecycle and to inform program-level projections.

Fees, Incentives, and the Program Plan

CAA expects to release illustrative base fees and incentive structures for California source reduction around May 1, 2026. This guidance is expected to provide an initial indication of potential malus fees and incentive credits. The accuracy of these illustrative ranges will depend on the completeness and quality of producer-reported supply data received before May 1.

Submitted baseline and ASR data will inform the draft California Program Plan, scheduled for submission to the SB 54 Advisory Board on June 15, 2026. A 60-day public comment period will begin after submission, providing a valuable opportunity for stakeholder input. CAA must consider the comments before submitting a revised Program Plan to CalRecycle in October 2026 (tentatively). 

The Program Plan timeline has significant implications for producers. SB 54 prohibits the sale or distribution of covered material in California beginning January 1, 2027 unless the producer complies on an individual basis or participates in an approved PRO. If CalRecycle approves the Program Plan before January 1, 2027, the restriction takes effect immediately. CAA has also indicated that early fee invoices may be issued in August 2026, with 2025 data informing both early fees (2026) and full program fees (2027).

De Minimis Determinations

SB 54 allows CalRecycle to establish thresholds for excluding “de minimis” packaging elements, such as certain coatings or labels. Packaging elements that meet the de minimis requirements could lead to lower producer fees, as they generally do not need to be reported to CAA. However, these thresholds have not yet been finalized, creating uncertainty in reporting scope.

Because regulations will determine the criteria and allow limited time for revisions after adoption, de minimis exclusions are unlikely to be reflected in initial ASR submissions. In the absence of thresholds, materials may be reported consistent with the current Covered Materials Category List.

Timeline Summary

The list below provides a summary of the upcoming deadlines described above relevant to California source reduction, though most are subject to change. 

• May 1, 2026: Regulations become effective (tentative); additional CAA source reduction guidance released (tentative)

• May 31, 2026: CAA’s reporting deadline, including for ASR Reports

• June 1, 2026: Regulatory deadline for producers to report to CAA (tentative: only if regulations become effective on May 1)

• June 15, 2026: CAA’s submission of California Program Plan to the Advisory Board, triggering a 60-day public comment period (tentative)

• June-July 2026: CAA’s deadline for submission of ISR Plans (tentative)

• August 2026: CAA issues early fee invoices (tentative)

• October 2026: CAA submits revised California Program Plan to CalRecycle (tentative)

• January 1, 2027: California sales prohibition begins (tentative: can be triggered earlier upon CalRecycle’s approval of the Program Plan)

Conclusion

The complex landscape of SB 54 requirements underscores the precision required for source reduction compliance. As the potential June 1, 2026, regulatory deadline approaches for finalizing 2023 baseline data and the first Annual Source Reduction Reports, the intersection of California’s specific mandates with broader multi-state and Canadian reporting cycles creates a significant challenge for producers. Achieving the ultimate 25-percent reduction target by 2032 requires a foundational understanding of these immediate reporting mechanisms, as the data submitted today will serve as the benchmark for measuring program-wide progress for years to come.  

EPR Group can assist companies navigate source reduction requirements, analyze applicability, and strategize compliance within the context of the broader EPR packaging landscape.

[1] Because certain materials are only available to registered producers, this article does not reference any of those materials; however, CAA has also made extensive information available to the general public. For clients that have registered with CAA, EPR Group can discuss and share the guidance documents available to registered producers.

[2] As to all confidential information included in submissions under SB 54, including this report, producers should seek legal advice about whether any information should be designated as trade secrets before submission.

Emma Roos-Collins is a Senior Policy Advisor at EPR Group.