California's Senate Bill 54
California’s Senate Bill 54 is a comprehensive packaging and waste management law that sets ambitious targets for reusable, recyclable, and compostable packaging, as well as overall plastic reduction. SB 54 establishes an extended producer responsibility framework that every producer who sells packaging in the state must comply with. In addition to reporting sales data and paying the associated fees for the materials they sell, producers must also submit individual source reduction plans that detail the specific changes they will make to their packaging to comply with the law’s plastic reduction targets.
Source Reduction Targets
SB 54 mandates that the amount of plastic that producers can collectively supply to the California market must be incrementally reduced by weight and number of components. A portion of that reduction must be achieved by shifting to reusable or refillable formats, or by eliminating plastic components all together. These targets are given as percentages, using supply data from 2023 as the baseline for comparison:
2027*
10% reduction of 2023 plastic supply
2% of 2023 plastic supply must be transitioned to reuse/refill or eliminated all together
2030*
20% reduction of 2023 plastic supply
4% of 2023 plastic supply must be transitioned to reuse/refill or eliminated all together
2032*
25% reduction of 2023 plastic supply
10% of 2023 plastic supply must be transitioned to reuse/refill or eliminated all together
* Reporting years reflect prior-year supply data
Reporting Requirements
Every producer who places covered materials on the market in California is required to report the amount of plastic they supplied in 2023. Beginning in 2026, producers must also submit annual reports detailing the amount of plastic they sold, offered for sale, or distributed (by weight and number of components) and the changes they made to their packaging in order to reduce the amount of plastic they supplied.
Pathways to Source Reduction
There are five pathways for producers to meet the plastic reduction targets.
Pathway 1: Reuse/Refill
The first pathway is shifting from single use packaging to refillable or reusable packaging. An example of refill-at-home packaging includes switching from a single-use plastic container to a refillable parent container that is refilled multiple times by the consumer with a large format single-use child package. A reusable system could involve switching from a single-use plastic package to a package that is designed to be returned by the consumer for the producer to wash and redistribute back into the reuse system.
Pathway 2: Elimination
The second pathway is eliminating a plastic component without replacing it with another component. An example of this would be removing a label from a package without replacing it and instead printing directly onto the packaging.
Pathway 3: Switching to Alternative, Non-Plastic Materials
The next pathway is switching from plastic to a non-plastic covered material. Source reduction targets only pertain to plastic packaging. Therefore, switching from plastic to glass would decrease a producer’s plastic supply in accordance with source reduction targets and the increase to their glass supply would not affect source reduction targets associated with SB 54.
Pathway 4: Right-sizing: Concentrating, Lightweighting, and Shifting to Bulk Packaging
Concentrating, lightweighting, and shifting to bulk packaging, collectively referred to as right-sizing, is another pathway to meet the source reduction targets. Notably, producers cannot change their recyclable packaging to a package considered non-recyclable or less likely to be recycled or composted. Meaning, producers cannot change from a plastic recyclable bottle to a plastic flexible pouch to meet source reduction targets.
Pathway 5: PCR Content as Alternative Compliance
The final pathway is using post-consumer recycled (PCR) content to help meet source reduction targets. Alternative compliance allows for more plastic to be supplied into California than the targets allow for, as long as it is PCR content validated by a third-party. The CAA is allowed to claim up to 8% of the PCR supplied into California as alternative compliance and the CAA will provide a formula instructing producers how to report their PCR content. Producers can use alternative compliance to meet right-sizing targets; it cannot apply to reuse, refill, or elimination targets.