CalRecycle Cuts SB 54 Plastic Baseline to 1.03 Million Tons

CalRecycle has lowered the 2023 plastic baseline for California's SB 54 source reduction requirements from 2.9 million tons to 1.03 million tons, a cut of nearly two-thirds in the figure producers must measure their future reductions against.

The updated Source Reduction Baseline Report, released Monday, draws on data reported by producers themselves. It counts 1.03 million tons of plastic covered material and 222 billion plastic components sold or distributed in California in 2023. While the tonnage fell sharply from the earlier estimate of 2.9 million tons, the component count rose from a previous 171.4 billion.

Under SB 54, producers must collectively achieve 25% source reduction from the 2023 baseline by 2032, with interim targets of 10% by 2027 and 20% by 2030. A lower baseline means fewer tons must be removed to hit each target.

Who supplied the data?

CalRecycle originally issued the baseline report on Dec. 31, 2024, using its own estimates for plastic weight and component counts associated with covered material sold, offered for sale or distributed in the state in 2023.

The revision rests on calculations by producer responsibility organization Circular Action Alliance, which collected company-level data from registered producers earlier this year. "The updated source baseline includes data from 2,127 producers of plastic covered material, accounting for about 50% of total participant producers," CalRecycle said.

Circular Action Alliance reviewed producers' individual source reduction plans but did not submit them individually to CalRecycle. Those documents were also supposed to detail source reduction achieved over the previous decade.

What does the lower baseline change?

Researchers at the Benioff Ocean Science Laboratory at UC Santa Barbara flagged the stakes before the update. They compared preliminary producer estimates against landfill characterization studies and wrote to CalRecycle with concerns.

The update "has consequences beyond accounting," Alex Fox, communications specialist with the lab, said in an email sent before the new numbers were published. "A baseline that starts too low shrinks the amount of plastic producers must eliminate."

After reviewing the updated report, Fox said the group was "surprised to see the mass for the updated baseline number go down and the number of items go up."

CalRecycle acknowledged that "not all producers have submitted accurate data" and said producers not yet reflected in the calculation "will be included in a future correction."

Which reduction methods count?

SB 54 allows producers several paths to the targets:

• Reusable or refillable alternatives, which must supply 10% of the requirement by 2032
• Eliminating unnecessary plastic
• Substituting non-plastic materials
• Rightsizing or lightweighting packaging

Producers can also count postconsumer recycled plastic for up to 8% of the source reduction requirement in any year.

What comes next?

CalRecycle's SB 54 advisory board meets again Friday to discuss Circular Action Alliance's revised program plan for packaging EPR in California. The agency has 75 calendar days from CAA's Oct. 13 submission to decide whether to approve it. A further baseline correction, once missing producer data arrives, could move the reduction math again.