California's Individual Source Reduction Plan: What to Include Before August 1
June 30, 2026 · 12 min read
California's SB 54 source reduction requirement didn't end after the May 31 reports. Producers also need a forward-looking Individual Source Reduction Plan (ISR Plan), due August 1, 2026. This guide covers what the ISR Plan requires, how it differs from the Annual Source Reduction Report, and a checklist to prepare before submitting through Circular Action Alliance.
At a glance
What is the Individual Source Reduction Plan?
The ISR Plan is a one-time, forward-looking plan that tells CAA how a producer expects to reduce plastic covered material over time. CAA's Producer Resource Center lists California's 2026 reporting items separately:
- May 31, 2026: Baseline Producer Report (CY 2023 data)
- May 31, 2026: Annual Supply Report (CY 2025 data)
- May 31, 2026: Annual Source Reduction Report (CY 2025 data)
- August 1, 2026: Individual Source Reduction Plan
That fourth item is easy to miss because it isn't just another annual report. It's the plan CAA uses to understand how producers intend to contribute to California's plastic source reduction goals.
ISR Plan vs. Annual Source Reduction Report
These are two separate filings. Make sure your team understands the difference before August 1.
| Question | ISR Plan | Annual Source Reduction Report |
|---|---|---|
| Timing | One-time submission | Annual filing |
| Deadline | August 1, 2026 | May 31 each year |
| Data type | Forward-looking projections | Prior-year actuals |
| Data years | 2026, 2029, 2031 projections for 2027, 2030, 2032 milestones | Prior calendar year |
| What it shows | Planned reductions across pathways | Actual plastic weight, component count, and actions taken |
| Historical credit | May include optional 2013-2022 reductions | Generally focuses on annual actuals |
A simple way to think about it: the Annual Source Reduction Report answers "what did you actually do?" The ISR Plan answers "what are you committing to do next?"
What is required in the ISR Plan
Based on CAA's resource center and source reduction guidance, prepare the following data before opening the ISR Plan workbook or Producer Portal workflow.
1. Your 2023 baseline plastic weight and component count
Your plan starts with your California 2023 baseline. Source reduction is measured against a fixed 2023 baseline by both plastic weight and plastic component count. There is no business growth adjustment: if sales grow, your baseline does not grow with it.
You need both numbers:
- Total plastic weight supplied into California in 2023
- Total plastic component count supplied into California in 2023
2. Historical reductions from 2013-2022 (optional credit)
Historical reductions from 2013-2022 may be reported for optional credit. If you want to claim them, gather:
- Packaging specifications before and after each change
- Sales volume by year or SKU
- Plastic weight per unit before and after
- Plastic component count before and after
- Documentation showing the change occurred between 2013 and 2022
3. Projected plastic weight and component count for 2026, 2029, and 2031
The ISR Plan is forward-looking. You must project plastic weight and component count for:
4. Planned reduction actions across five pathways
Every action in your ISR Plan must be assigned to one of five approved source reduction pathways:
Switch from single-use packaging to producer-managed reusable or refillable formats. Examples: refill stations, returnable containers, refill-at-home concentrate systems.
Remove plastic components entirely. Includes bring-your-own-container models where the producer no longer supplies packaging. Examples: remove plastic window from box, eliminate plastic insert.
Shift from plastic covered material to non-plastic covered material. The replacement material must be valid under California's covered material rules. Examples: PS tray to paperboard, PET bottle to aluminum can.
Reduce plastic per unit through smaller formats, lighter packaging, concentrates, or bulk formats. Examples: 2x concentrate in smaller bottle, lightweight bottle from 24g to 18g, bulk format.
Increase certified post-consumer recycled content. Can contribute up to 8 percentage points toward the collective 25% goal. Credit is based on the increase vs. 2023 baseline, not total PCR used. Third-party certification required.
5. Certified PCR usage
If you plan to claim PCR as part of your reduction strategy, document:
- Resin or material type
- 2023 baseline PCR percentage
- Projected PCR percentage by target year
- Virgin plastic displaced
- Third-party certification or supplier certification
Important: PCR credit is based on the increasein PCR content compared to your 2023 baseline, not the total amount of PCR you use. Don't double-count PCR as both a PCR credit and a physical weight reduction unless the packaging also uses less plastic.
6. Explanations for how reductions will be achieved
For each planned action, include a plain-English explanation:
- What SKU, product line, or packaging component changes
- Why the change is technically feasible
- Which supplier, packaging format, or operational change is involved
- When the change will be implemented
- What internal owner is responsible
- What evidence will prove completion later
This is the difference between a credible plan and a spreadsheet target.
7. Aggregate source reduction activity
CAA tracks more than just net reduction against the baseline. The framework distinguishes between:
Net Source Reduction
Your actual plastic weight (or component count) in a target year vs. your 2023 baseline. This is the regulatory requirement. If your business grows, your absolute plastic footprint grows with it; your target does not adjust.
Source Reduction Activity
The reduction you achieved through specific design or operational changes, regardless of overall growth. CAA tracks this too, so even if business growth offsets your net reduction, your efforts are documented.
The key calculations
Three equations apply depending on the type of reduction. Using the right one determines how your effort is credited.
Net Source Reduction
(2023 baseline plastic weight or count) − (target-year plastic weight or count) ÷ (2023 baseline plastic weight or count)
Absolute reduction regardless of sales growth.
Equation A: Design-enabled changes
SR Activity = Σ [ (Weight per unit in 2023 baseline − Weight per unit in target year) × Unit sales in target year ]
Use for: lightweighting, component elimination, concentration, bulk formats, material switching.
Equation B: Sales-enabled changes
SR Activity = Σ [ Weight per unit in 2023 baseline × (Unit sales in 2023 − Unit sales in target year) ]
Use for: elimination due to sales reduction, complete removal of a SKU from the California market.
Equation C: Shifts to reusable/refillable formats
SR Activity = Σ [ Weight per unit of single-use packaging in 2023 baseline × Unit sales in target year in reusable packaging ]
Use for: producer-managed reuse/refill systems, BYOC elimination pathway.
Example: Tea pouch lightweighting
2023 baseline: 10,000 units × 0.8 lb = 8,000 lb
2025 actual (lightweighted): 10,500 units × 0.5 lb = 5,250 lb
SR Activity (Equation A): (0.8 − 0.5) × 10,500 = 3,150 lb credited
Net SR vs. 2023:8,000 − 5,250 = 2,750 lb
Even though you sold 500 more units (business grew), the per-unit plastic reduction resulted in a net 2,750 lb decrease vs. baseline. CAA tracks both the activity metric (3,150 lb) and the net reduction (2,750 lb).
What doesn't count (or needs caution)
- No sales growth adjustment: The target is absolute. Growth can erase net reduction even if per-unit packaging improves.
- Recyclability alone isn't source reduction: Making packaging more recyclable is valuable, but it doesn't reduce plastic weight or component count by itself.
- Switching to worse material: Switching from recyclable/compostable to non-recyclable/non-compostable material does not count.
- Unverified material switching: Verify the destination material is valid under California's covered material rules.
- BYOC classification: Bring-your-own-container models may classify as Elimination, not Reuse/Refill, because the producer is not managing reusable packaging.
- Overstating PCR: PCR credit is tied to the increase over the 2023 baseline and requires certification.
- Overcommitting: The ISR Plan is a binding agreement. Don't project reductions you cannot execute.
ISR Plan checklist
Baseline data
- Confirm your company is a California producer under SB 54
- Confirm whether you are filing through CAA or independently
- Pull CY 2023 Baseline Producer Report: total plastic weight and component count
- Confirm units are consistent across baseline and projected years
Historical reductions (if claiming 2013-2022 credit)
- Identify packaging changes completed between 2013 and 2022
- Gather before/after packaging specifications and sales volume
- Calculate weight and component count reduction per change
- Map each historical change to the correct pathway
Forward projections
- Project 2026 plastic weight and component count
- Project 2029 plastic weight and component count
- Project 2031 plastic weight and component count
- Tie projections to real sales forecasts, SKU plans, and supplier timelines
- Review whether plan still reduces absolute plastic if CA sales grow
Planned actions
- List every planned source reduction action
- Assign each action to one of the five pathways
- Identify affected SKUs, product families, and packaging components
- Estimate weight and component count reduction per action
- Identify implementation owner and target date
- Gather support documents: spec sheets, supplier quotes, test results, certifications
PCR claims
- Record 2023 baseline PCR percentage and projected PCR by target year
- Calculate virgin plastic displaced
- Gather third-party certification or supplier documentation
- Confirm PCR is not double-counted as both PCR credit and physical weight reduction
Calculations
- Calculate source reduction activity for each action
- Calculate net reduction vs. 2023 baseline
- Calculate reduction by plastic weight and by component count
- Calculate reduction by pathway and in total
- Reconcile action-level totals to company-level totals
Submission readiness
- Review CAA's current ISR Plan workbook or portal workflow
- Confirm all required fields are complete
- Confirm reductions are achievable and approved internally
- Get legal/compliance review
- Save a copy of the submitted workbook or portal confirmation
- Set calendar reminder for annual source reduction reporting updates
Common mistakes
1. Treating the ISR Plan like a narrative sustainability report
The ISR Plan needs quantifiable reductions by weight and component count, not a story about sustainability goals.
2. Only planning for weight
California source reduction also tracks plastic component count. A plan that only reduces grams may miss a second reporting dimension.
3. Ignoring 2029 and 2031
The plan is not only about 2026. It should project the supply years that correspond to all three milestones: 2027, 2030, and 2032.
4. Double-counting PCR and lightweighting
PCR content is an alternative compliance pathway. If the package also gets lighter, separate the PCR claim from the actual plastic weight reduction.
5. Overcommitting to unapproved packaging changes
A planned switch isn't real until suppliers, operations, quality, and finance can support it. The ISR Plan is a binding agreement. Build something achievable and defensible.
A practical ISR Plan table
Before opening the portal, build a working table like this for each planned action:
| Field | Example |
|---|---|
| Product line | 12 oz shampoo |
| Component | HDPE bottle |
| 2023 baseline weight | 24 g per unit |
| Target-year weight | 20 g per unit |
| Target year | 2026 |
| Unit forecast | 500,000 units |
| Pathway | Concentrating / right-sizing / lightweighting |
| SR activity | (24 g − 20 g) × 500,000 = 2,000,000 g |
| Evidence | Supplier spec sheet, purchase order, packaging drawing |
| Owner | Packaging engineering |
| Status | Supplier quote received |
This table becomes the bridge between packaging operations and the ISR submission.
Three CA filings, two deadlines
Establishes your 2023 baseline weight. See the supply report guide →
Packaging weight by material: your fee basis. See the supply report guide →
Documents reduction actions and progress vs. 2023 baseline. See the source reduction report guide →
Your forward-looking roadmap for meeting 2027/2030/2032 milestones. One-time filing.
Official resources: CAA California Portal · CAA Producer Resource Center · CAA Reporting · CalRecycle SB 54 · EPR Fee Check: California