How to File the California Source Reduction Report (SB 54)
May 16, 2026 · 11 min read
The California Source Reduction Report is a separate filing from the Annual Supply Report. It documents what you have done to reduce plastic packaging compared to your baseline year. This guide covers the targets, qualifying actions, baseline methodology, and the ISR Plan.
At a glance
The reduction targets
SB 54 sets mandatory plastic packaging reduction milestones measured against your CY 2023 baseline:
Important: these targets apply to total plastic packaging weight, not individual material types. Up to 8 percentage points of your reduction can come from increased PCR content (substituting virgin plastic with recycled content). The rest must come from actual source reduction — less plastic, lighter plastic, or no plastic.
Establishing your baseline
The CY 2023 baseline comes from your Baseline Producer Report (also due May 31, 2026). This is a separate filing that reports your total plastic packaging weight sold into California during calendar year 2023.
If you were in business in CA during 2023
File your Baseline Producer Report with actual 2023 data. Your baseline is the total plastic packaging weight you sold into CA that year. All future reduction percentages are measured against this number.
If you were not in business in 2023
File the Baseline Report with zero and document why (new business, no CA sales in 2023). Your first full year of CA data becomes your functional baseline. PRC §42051(b)(1) provides a 6-month grace period for entities that become obligated after January 1, 2027.
If you were under the $1M threshold in 2023
If you were below the exemption threshold in 2023 but above it now, report zero for 2023 and use your first obligated year as the baseline. The year you crossed $1M in CA revenue is year one for reduction targets.
If you were obligated in 2023 but didn't file
You are still responsible. File the Baseline Report with reconstructed data from 2023 sales records, packaging specs, and shipping data. Late filing with best-available data is far better than non-filing. Penalty exposure is up to $50,000/day.
How reduction is calculated
% Reduction = (Baseline plastic weight − Current plastic weight) ÷ Baseline plastic weight × 100
Only plastic packaging counts toward source reduction. Substituting plastic with paper, aluminum, or glass reduces your plastic weight — which counts — but the substituted material is not part of the source reduction calculation itself.
Example: Your 2023 baseline was 10,000 kg of plastic packaging sold into CA. In 2025, you switched 2,000 kg of PS trays to paperboard. Your 2025 plastic weight is 8,000 kg. Reduction = (10,000 − 8,000) ÷ 10,000 = 20%. You have met the 2027 target early.
Qualifying source reduction actions
Not all reductions count equally. SB 54 prioritizes elimination and reuse over lightweighting:
| Action Type | Examples | Counts Toward Target? | Documentation Needed |
|---|---|---|---|
| Elimination | Remove plastic window from box, eliminate plastic insert, remove shrink wrap | Yes — highest priority | Before/after weights, SKU comparison |
| Reuse / Refill | Launch refill program, switch to returnable containers, implement refill stations | Yes — required for at least 10% of target | Program records, refill rates, participant data |
| Material substitution | Replace PS tray with paperboard, switch PET bottle to aluminum can | Yes — reduces plastic weight | Spec sheets showing material change |
| Concentration | Concentrate product 2x, reducing bottle size and label area | Yes — reduces total packaging per use | Formula records, before/after packaging weights |
| Right-sizing / Lightweighting | Reduce bottle weight from 24g to 18g, downsize shipping box | Yes — but lowest priority | Spec sheets, purchase orders |
| PCR content increase | Increase PCR from 0% to 30% in PET bottles | Yes — up to 8 percentage points of target | Supplier certifications, resin purchase records |
The Individual Source Reduction Plan (ISR Plan)
In addition to the Source Reduction Report, California requires an Individual Source Reduction Plan — a separate filing due August 1, 2026. This is your roadmap for meeting future reduction targets.
The ISR Plan must include:
- Current baseline — your CY 2023 total plastic packaging weight sold into CA
- Current reduction percentage — where you stand as of CY 2025 data
- Planned actions — specific elimination, reuse, substitution, and lightweighting initiatives
- Timelines — when each initiative will be implemented (2026, 2027, 2028+)
- Expected reduction — projected kg reduction from each action
- Milestone targets — how you will meet 10% by 2027, 20% by 2030, 25% by 2032
If this is your first year filing, the ISR Plan is mandatory. It is filed separately from the Source Reduction Report, so plan your time accordingly.
Three filings, two deadlines
California has three distinct filings with 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.
Your roadmap for meeting 2027/2030/2032 milestones. Required for first-time filers.
Filing checklist
- Pull your CY 2023 total plastic packaging weight (from Baseline Producer Report)
- Identify all reduction actions taken during CY 2025 (elimination, reuse, substitution, lightweighting, PCR increase)
- Gather documentation: before/after weights, spec sheets, program records, supplier certifications
- Calculate CY 2025 total plastic packaging weight sold into CA
- Calculate % reduction: (Baseline − Current) ÷ Baseline × 100
- Verify that at least 10 percentage points come from reuse/refill/elimination (not just lightweighting)
- Enter reduction data in CAA Producer Portal under Source Reduction Report
- Draft Individual Source Reduction Plan (due August 1, 2026)
- Submit both the Source Reduction Report and Supply Report before May 31, 2026
Official resources: CAA California Portal · CalRecycle SB 54 · CAA Producer Resource Center · EPR Fee Check — California