Last week, rePurpose Global sponsored and participated in the Source Reduction Summit, a full two days of working sessions bringing together CPG producers, converters, material associations, legal advisors, and policy experts to work through the practical realities of California's SB 54 source reduction requirements. We left with new connections and a clearer picture of where the industry actually stands. Hint: we’re all learning as we navigate this new regulation together. 

Here is what matters most for CPG compliance, packaging, and sustainability teams trying to figure out their next move.

1. The whole field is at 2.5 out of 5. You are not behind.

The summit opened with live anonymous polling, a deliberate move to cut through the usual conference posturing. When producers were asked to rate their internal readiness on a five-point scale, the median answer was 2.5, defined as "still building basic internal awareness of what EPR means for our teams."

This was a room of relatively engaged companies, and the median sat halfway to "we understand what this requires of us." That number matters because EPR work tends to happen in silos, with each team assuming it is further behind than its peers. The polling showed the opposite: the field is clustered around the same early-to-mid stage of internal coordination. The anxiety concentrating on the producer side is real, but it is widely shared.

The framing that followed was practical: the goal right now is not a perfect plan — it's a realistic one. That means identifying the reduction levers your team can actually execute before the August deadline, understanding which packaging components are candidates for near-term action, and building cross-functional alignment so the plan doesn't stall in internal review. "Implementable" was the word that came up again and again; a plan you can actually deliver matters more than one that looks ambitious on paper.

2. This became a financial problem the moment a malus figure was published

The shift that changed the tone of the room was the publication of illustrative malus fee estimates by the Circular Action Alliance. Once there is a dollar figure attached to virgin plastic, EPR stops being an abstract sustainability commitment and becomes a line item that finance can model against alternatives.

The producer panel was direct about the implication: pull procurement in now. Procurement is built to handle trade-offs expressed in dollars per pound, and it has been underused in EPR planning precisely because the obligation has felt like a sustainability team issue. With a known malus figure expected in 2027 and payment in 2028, that framing no longer holds. The Circular Action Alliance has already published illustrative fee estimates and incentive-mechanism guidance in the producer portal before the program plan is final, specifically so producers can model the financial impact of their choices now.

3. Tertiary and secondary packaging is the fastest near-term win

Across sessions, one piece of tactical advice came up consistently enough to call it consensus: start with tertiary and secondary packaging.

It is not consumer-facing, so it sidesteps the brand-identity and marketing debates that slow primary package decisions, and it usually carries a cost-savings story alongside the compliance one. The technical case is strong. A converter at the summit described moving post-consumer recycled content into bundle and shrink film, stepping up from 25% to 50% PCR at the same film gauge. Holding the gauge constant is the critical detail, because it means virgin plastic is genuinely displaced rather than quietly offset by making the film thicker. The transition held through freeze-thaw cycles, had minimal visual impact, and stayed stable in production.

Shrink film tolerates recycled content far better than stretch film, where a single gel or pinhole is a performance failure. That makes collation and bundling film the most replicable near-term entry point for brands that want a proof of concept before tackling harder formats.

The broader principle worth taking from that session: different components of the same package have different jobs. A yogurt tub and its sealing lid do hard food-protection work; the overcap does not. Starting with the low-stakes components across your portfolio lets you capture real reductions without touching the formats where the technical risk is highest.

4. PCR has a certification gap most producers have not found yet

The panel flagged a timing risk worth knowing early: in this first compliance cycle, only APR-certified PCR qualifies toward the source reduction targets, and most of the PCR that producers are currently sourcing is not APR-certified.

Certification takes time, and some existing suppliers may not be able to get it before the deadline. Producers planning to lean on the PCR pathway could find that gap only after it is too late to close it. This is a conversation to start with your converter and resin supplier now, well before Q4 planning.

On the mechanics: post-consumer recycled content counts toward up to 8% of the overall 25% reduction target at the PRO level, and the Alternate Compliance Formula counts it roughly one-for-one. Performance quality depends heavily on feedstock. The case study that ran stably in production used a clean, closed-loop stream rather than mixed curbside bales, and that feedstock quality was what allowed the recycled content to perform like virgin material. Mixed bales produce inconsistent results; closed-loop streams do not.

5. A realistic, implementable plan beats an ambitious plan you can’t execute

If there was a single theme that ran through every session at the summit, it was this: the goal right now is not a perfect source reduction plan — it's an implementable one. The word came up repeatedly, and deliberately. Regulators and peers alike are not expecting brands to have solved packaging sustainability by August. They are expecting a credible, executable commitment that reflects what your team can actually deliver.

What makes a source reduction plan implementable in practice comes down to a few things the summit kept returning to:

Start with a component-level audit of your portfolio. You cannot build a reduction plan without knowing what you have. That means mapping your packaging at the component level — not just "we use a lot of plastic" but which components, in which formats, at what weights, across which SKUs. This is the foundation everything else builds on, and it is also the data that feeds annual reporting, so building it well now pays forward.

Identify your near-term levers before your long-term ones. Not every packaging component is equally ready for change. A realistic plan sequences the work — tertiary and secondary first, low-stakes overcaps and accessories before primary food-contact formats, proven PCR transitions before unproven ones. Mapping your portfolio against technical feasibility and business risk tells you where to start and what to save for later cycles.

Get the right people in the room early. Source reduction is not a sustainability team problem. It is a procurement problem, a finance problem, a supply chain problem, and a marketing problem depending on which component you're looking at. The brands that are furthest along have one thing in common: they pulled those functions in before the plan was written, not after. Cross-functional alignment is not a nice-to-have — it is what makes a plan implementable rather than theoretical.

Write the plan to reflect reality, not aspiration. If a reduction depends on a supplier transition that hasn't closed yet, say so and give a timeline. If a component is on the roadmap for the next cycle rather than this one, name it. Plans that acknowledge constraints and sequence work realistically are more credible to reviewers — and more useful internally — than ones that overcommit and underdeliver.

The summit closed with a clear message: the brands that treat this first cycle as a foundation-building exercise, not just a filing exercise, will be in a materially better position in 2027 and 2028. An implementable plan you can actually execute — and learn from — is worth far more than an ambitious one that stalls.

6. Good data built now becomes the infrastructure that carries you through annual reporting

The thread running under every session was data quality. The ISRP equations used to measure source reduction activity are the same equations used every spring for the annual report. A packaging database built correctly this summer becomes reusable compliance infrastructure; built as a one-off spreadsheet for this submission, it has to be rebuilt from scratch next year.

What "built correctly" means in practice: a structured, component-level database with the right attributes attached to each SKU, and one that can be modeled against multiple scenarios simultaneously — California fees, SB 343 recyclability classifications, PCR mandates, multi-state EPR requirements — and updated as the regulatory picture shifts.

The complexity is compounding faster than most teams realize. The number of US packaging categorization rules in our platform grew from roughly 300 to 650 in a single year. California alone accounts for around 265 of them, several times the average state. One of our team members described it in the room as "everything everywhere all at once," and while it was said as a joke, it resonated because it captures the planning reality accurately.

Teams that treat this first cycle as infrastructure-building — establishing the data model, the internal process, the cross-functional ownership — will find the 2027 and 2028 reporting cycles significantly more manageable than those who file something for August and start over next spring.

What comes next

The industry will not fully know where the real SB 54 pinch points are until the first ISRPs are aggregated and reviewed collectively, and the summit closed with a commitment to reconvene in roughly six months once that picture exists. What will separate the teams that are ready for that conversation from those scrambling to catch up is whether they built their data foundation now, while there is still time to model options and make deliberate decisions before the August deadline.

In the meantime, the practical sequence for most CPG teams: pull procurement and finance into the planning process, start APR-certification conversations with suppliers before the gap surfaces, identify tertiary and secondary packaging opportunities that can move quickly, and invest in building a data foundation that survives the annual reporting cycle beyond the August deadline.

For teams working through the ISRP process right now, rePurpose Global is launching a Packaging Simulator that lets you instantly model the impact of packaging decisions before you commit to them. Enter a component swap, a lightweighting change, or a shift to PCR content, and see the projected effect on EPR fees, recyclability, and CA source reduction targets in real time — no spreadsheets, no months of manual analysis. If you want to be among the first to access it, book a demo.

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rePurpose Global sponsored and participated in the Source Reduction Summit. Per the event's Chatham House Rule, session insights are shared here without attribution to specific individuals or companies.

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