California's SB 54 Source Reduction: 10% Cut Due Jan. 1, 2027

Producers selling packaged goods in California face a producer responsibility organization-wide target to cut the overall weight and number of plastic components by 10% by Jan. 1, 2027, under the state's SB 54 extended producer responsibility law.

Individual source reduction plans, based on 2023 data, were due to the producer responsibility organization Circular Action Alliance in early August. Each producer outlined a path through some combination of five levers:

• eliminating material
• implementing reuse and refill
• lightweighting
• substituting materials
• incorporating post-consumer recycled content

Who is actually accountable?

California regulators will not receive the individual producer plans. Linnea Whitney Skierski, deputy director in the Office of Policy Development and Analysis at CalRecycle, said the data CalRecycle sees will be anonymized through what CAA reports in its program plan.

"Nobody is going to be held specifically accountable to meeting certain source reduction requirements. You're supposed to work together as a team to identify the best opportunities that would work for you," Skierski said at the SPC Advance conference in San Diego on Sept. 28, 2026.

The PRO-wide approach reflects a practical reality: some brands and product types offer more low-hanging fruit than others. The ultimate PRO-wide goal is 25% source reduction pegged to 2032, with 10 percentage points of that coming from reusable and refillable solutions.

Where does reuse fit in?

Ellie Moss, executive director of the nonprofit reuse firm Perpetual, said many producers feel "sheer terror" at the prospect of implementing reuse. She pointed to untapped changes consumers will never see, such as B2B transit packaging for back-of-house food delivery.

"You're getting buckets of pickles, you're getting big tubs of mayonnaise, you're getting these very large, often very heavy pieces of packaging that are then going straight to the dumpster, but could absolutely be refilled," Moss said.

Will this spread to other states?

Stakeholders expect source reduction requirements to become increasingly relevant beyond California. Minnesota, Washington and Maine have source reduction targets in their packaging EPR programs, with potential for harmonization in future states.

CAA is developing and tweaking a detailed incentive structure tied to the source reduction goal. Producers will submit individual source reduction plans each year if they have an update, said Dave Lefebvre, policy advisor with CAA.

"That task will allow us to dial in the right incentives to pursue the targets as quickly as possible, but as economically efficient as possible," Lefebvre said.

CAA's revised program plan goes to CalRecycle next Tuesday, and an SB 54 advisory board meeting follows next Friday. "Our primary focus on ecomodulation is accelerating source reduction," CAA Chief of Staff Shane Buckingham said in a Q&A on implementing California's packaging EPR program at SPC Advance.

With the 2027 milestone under a year away and annual plan updates feeding CAA's incentive design, brands that move early on lightweighting, reuse and material substitution stand to shape both compliance costs and program economics.