CalRecycle Updates Its SB 54 Source Reduction Reporting Guidance

July 28, 2026 Perspectives

On July 17, 2026, CalRecycle updated its SB 54 Source Reduction Reporting Guidance, which was originally published on September 2, 2025.

As a reminder, SB 54 is California’s extended producer responsibility (EPR) law for packaging, and its official name is the Plastic Pollution Prevention and Packaging Producer Responsibility Act.  Source reduction mandates in SB 54 apply to plastic-covered materials, and percentage reductions in plastic weight and the number of plastic components are specified for 2027, 2030, and 2032.

CalRecycle’s updated guidance provides, among other things:

  • That the source reduction mandates for plastic covered materials are a collective responsibility to be achieved via the Producer Responsibility Organization (PRO), rather than being applicable to individual Producers or covered material categories.
  • That each Producer’s Individual Source Reduction (ISR) Plan will inform the collective source reduction plan prepared by the PRO, and is not a binding commitment by Producers.
  • That the source reduction plan prepared by the PRO is to be part of the PRO Plan, which must be submitted to CalRecycle by October 13, 2026, for approval by January 1, 2027.

Note that the approved PRO is the Circular Action Alliance (CAA). CAA submitted a draft PRO Plan to the SB 54 Packaging Producer Responsibility Advisory Board on June 15, 2026, and the public comment period on that Plan ends on August 14, 2026.  CAA has set a deadline for Producers to submit ISR Plans to CAA of August 3, 2026.

CalRecycle’s updated SB 54 Source Reduction Reporting Guidance can be found here, and additional guidance from CalRecycle can be found on its Producer Guidance webpage