California Source Reduction 101: Navigating the 5 Pathways

Source reduction is one of the most misunderstood requirements of California SB 54. Our new guide breaks it down from the ground up: what source reduction actually means under the law and how each of the five pathways works in practice.

With the August 1 Individual Source Reduction Plan deadline approaching, there's no room for guesswork. This guide gives you the foundation to walk into your CAA submission with confidence.

What’s in the guide:

Defining SB 54 California source reduction along with CAA and individual producer source reduction targets

Plastic definitions and how to report plastic weights and components

Introduction to the 5 source reduction pathways: Refill/Reuse, Elimination, Right-Sizing, Material Substition, and Alternative Compliance (PCR Content)

Real implementation constraints to help you determine which pathways make sense for your packaging portfolio; learn where brands typically hit walls with each pathway

Steps to building your ISR Plan and how the rePurpose Packaging Simulator can help

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Your Week-by-Week Route

Base Camp: Assess Obligation

Assess your North American EPR obligation by revenue threshold, covered material categories, and more.

Camp 2: State Mapping

Map your materials to each state's varying material categories. Different trail, same summit.

Camp 4: Fee Review

Model your fee exposure. Double-check your material classifications to minimize EPR fees.

Summit

Submit your reports. Plant your flag. You've reached the summit! Look ahead to the next milestones, like the CA Source Reduction Plan due August 1.

Sept 22, 2025

Reporting portal & CAISA

The reporting portal officially opened and the CAISA (State Addendum) was emailed to authorized producers for signature.

May 2026 (TBD)

2023 Baseline Report Submission / Validation

30 days after CA regulations are finalized, Producers will need to submit a 2023 packaging baseline report.

Camp 5: Final Review

ISR Plan Due and Pay Early Fees

No later than Aug 1, Individual Source Reduction Plans are due. In addition, early program fees will be issued to Producers.

Camp 1: Data Check

Confirm your packaging data is complete. Verify your sales-by-state numbers. If something is missing, flag it now.

Camp 3: California Focus

Review your 2023 baseline data. Identify your source reduction actions, and prepare your annual source reduction report.

Camp 5: Final Review

Review all reports. Check for errors. Confirm the submission process for each state. You're almost there.

Frequently asked questions

What you need to know about CA source reduction and the ISR Plan deadline.

California's Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54) requires covered producers to submit Individual Source Reduction (ISR) Plans demonstrating how they're reducing plastic packaging supplied into California over time to help meet CalRecycle's source reduction targets. If you sell packaged goods in California, you likely have reporting obligations. If you were an obligated producer for EPR reporting in California, you're also obligated to submit an ISR Plan.

Source reduction means making changes that reduce the amount of plastic at the source — before it becomes waste. That can include switching to lighter materials, reducing layers, increasing recycled content (PCR), or improving recyclability. To develop your source reduction plan, check out our Packaging Simulator, which helps you model the tradeoffs and changes with the biggest impact on your source reduction metrics so you're not guessing.

If you haven't filed your EPR reports (supply data report and annual source reduction report using calendar year 2025 data, as well as your 2023 baseline report), you'll still need to report if you're an obligated producer. It's not too late. rePurpose can still handle your data and help with your reporting before they deem you delinquent and implement non-compliance fees. Reporting portals are still open.

To prepare for the approaching ISR Plan deadline, CAA recommends starting with your 2023 baseline report right now so you don't miss the August 1 deadline. The 2023 baseline data precedes the ISR Plan. If you're a covered producer under the May 31 deadline, you're still a covered producer for source reduction and must submit an ISR Plan.

Everything in California EPR source reduction is measured against your 2023 packaging baseline. Getting this right and getting it submitted correctly is arguably the single most important task you have right now. It comes first in the source reduction reporting sequence.

Non-compliance can result in serious consequences including:
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Fines up to $50,000 per day in California
Sales bans and prohibition from selling products in regulated markets.
Public listing as non-compliant.
Reputational damage and business disruptions

The 25% source reduction target is a CAA/PRO obligation, which means it's a collective goal. Individual producers are not obligated to meet this 25% reduction goal but will have to do reductions at their own level for the collective to meet these targets.

You bring the data, and we’ll handle everything else.

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It's not too late. And we'll start with source reduction, specifically with your 2023 baseline data. In addition, we’ll need your 2025 packaging supply data, supplier specs and sales data by state, your team’s point person for EPR, and your packaging changes from 2025 for California source reduction tracking.

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We’ll provide you with a North American obligation assessment, material categorization and fee calculations, state-by-state report generation, California source reduction pathway classification, fee forecasting so you know what's coming before the invoice arrives, dedicated compliance experts reviewing everything and walking you through submission, and continual regulatory monitoring so that you don’t have to read through 1,000 pages as regulations evolve.

August 1, 2026.

With our new Packaging Simulator, rePurpose can help your team finalize a plan based on your source reduction pathway decisions. Our Simulator is purpose-built to help you fulfill the CA Source Reduction mandate. Please reach out to our team to learn more about how we can help you.

As of now, you are bound to the ISR Plan you submit. Changes will depend on whether or not CAA requires you to make a revision. CAA will review each producer's plan separately, and it will become an enforceable commitment.