Your SB 54 Source Reduction Plan Is Filed
Can It Hold Up?
California’s packaging EPR law has moved from planning to implementation.
SB 54 regulations took effect May 1, 2026. Producers have registered, submitted baseline and supply data to Circular Action Alliance, and filed individual source reduction plans. Now, the first major source reduction milestone is approaching: a 10% reduction in plastic packaging by January 1, 2027.
For many companies, developing the plan was only the first step. The work now is determining how those commitments translate into packaging decisions that can meet California’s requirements while still making sense for the product, the business, and the recycling system.
A Familiar Strategy with New Stakes
Source reduction itself isn’t new. Lightweighting, right-sizing, material substitution, recycled content, reuse, and refill have been part of sustainable packaging strategies for decades. What SB 54 changes is the context in which those decisions are being made.
The law establishes escalating source reduction requirements for plastic packaging: 10% by 2027, 20% by 2030, and 25% by 2032. Progress considers both plastic weight and the number of plastic components, while specific portions of the targets must be achieved through reuse, refill, or elimination. Other strategies, including the use of recycled content, have limits on how much they can contribute toward compliance.
That makes source reduction more than a packaging design exercise. Companies need to understand not only whether a change reduces plastic, but how it counts toward their targets, what it costs, how it affects package performance, and what it means elsewhere in the packaging and recycling system.
Finding the Right Pathway
The question isn’t as simple as
How do we reduce plastic?
The question is:
Which combination of strategies gives us a realistic path to compliance while balancing cost, performance, and system impacts?
No single source-reduction strategy works for every package or product. Each pathway comes with its own technical, operational, and economic considerations.
Take post-consumer recycled content (PCR). Increasing PCR may support source reduction goals, but companies still need to understand availability, quality, cost, performance requirements, and how the change affects both compliance and EPR fees. In some applications, maintaining package performance may require additional material, changing the overall calculation.
Material substitution brings a different set of considerations. Moving away from plastic may reduce plastic tonnage, but the alternative material still needs to work for the product and within California’s recycling system. A change that looks beneficial on a spreadsheet may create new challenges in collection, sorting, processing, or end markets.
Reuse and refill can offer significant source reduction opportunities, but only where the product, consumer behavior, infrastructure, and business model support them.
Connecting Packaging Decisions to the System
Answering which combination of strategies gives us a realistic path to compliance while balancing cost, performance, and system impacts requires looking beyond the package itself.
RRS has worked for decades at the intersection of packaging, materials management, recycling infrastructure, markets, and policy. That systems perspective helps companies evaluate source reduction strategies based not only on what is technically allowed, but on how materials and packaging actually move through the system.
Our work includes packaging and materials strategy, MRF flow testing, reclaimer and end-market research, recycling system analysis, and EPR implementation. That allows our team to connect decisions made upstream with what happens downstream.
RRS also works across the EPR ecosystem, including with producer responsibility organizations, government agencies, recyclers, and other system stakeholders. That gives our team a view into both the policy requirements and the practical realities of implementation.
For companies implementing SB 54 source reduction plans, RRS can help:
Stress-test existing plans to identify gaps, assumptions, and implementation challenges ahead of upcoming milestones.
Compare source reduction pathways across compliance contribution, cost, package performance, EPR fee implications, and system impacts.
Evaluate PCR strategies against real-world supply, quality, and end-market conditions.
Assess material and packaging changes in the context of collection, sorting, processing, and recyclability.
Build strategies across EPR programs so packaging decisions account for requirements emerging beyond California.
From Plan to Implementation
Filing a source reduction plan establishes the pathway. The next challenge is making sure that pathway works.
Whether you’re pressure-testing an existing SB 54 plan, comparing source reduction options, or determining how individual packaging changes fit into a broader EPR strategy, RRS can help connect the regulatory requirements to the technical and economic realities of implementation.
Attending SPC Advance this week?
Connect with RRS team to continue the conversation.
Anne Johnson
Erika Le
Joel Schoening
SK Klemann