California's SB 54 requires producers to collectively reduce plastic packaging by 25% through multiple pathways, including reuse, elimination, lightweighting, material substitution, and recycled content, with the first targets taking effect in 2027.
- 25% collective reduction target: Ten percentage points must come from reuse, refill, or elimination; 15 points from lightweighting, material substitution, optimization, right-sizing, or recycled content (up to 8 points).
- PRO-wide, not per-producer: The 25% goal applies across the entire producer responsibility organization, allowing companies with different packaging portfolios to contribute in different ways.
- 2027 deadline: The first source-reduction targets take effect in 2027, giving producers limited time to identify opportunities and make packaging changes.
- Incentive-based approach: The Circular Action Alliance uses tiered incentives rather than individual targets, recognizing different levels of progress and adjusting based on producer feedback.
- Multiple reduction pathways: Opportunities include eliminating overwrap, right-sizing packages, reusable bulk containers, distributed prefill models, and increasing recycled content in packaging, among others.
California’s SB 54 extended producer responsibility legislation for packaging is forcing brand owners to rethink how much plastic packaging they put into the market and where they can realistically reduce it. While the law’s 25% source-reduction requirement will be measured collectively across the producer responsibility organization (PRO), giving CPGs some flexibility in how they contribute to the goal, the short runway to the first targets means producers need to begin identifying realistic opportunities now.
The 25% requirement spans a mix of approaches. Ten percentage points must come from reuse, refill, or elimination, while the remaining 15 can come from strategies such as lightweighting, material substitution, optimization, and right-sizing. An alternative compliance pathway allows recycled content to account for up to eight percentage points of that second portion.
The urgency around those requirements was evident in the standing-room-only crowd at an opening session of the Sustainable Packaging Coalition’s SPC Advance 2026 event. Panelists focused on where companies should begin, how the Circular Action Alliance (CAA) plans to encourage action, and why different packaging formats will require different approaches.
A collective target; individual action
One of the most important distinctions for producers is that the 25% goal applies across the PRO rather than equally to every individual company.
“PRO-wide. Yes. Industry-wide to 25%, not producer by producer,” confirmed Dr. Anja Brandon, director of plastics policy at Ocean Conservancy.
Dylan de Thomas, vice president of public policy and government affairs at The Recycling Partnership and moderator of the session, said that structure was intentional. “We understood when we were sitting at the table that 25% is really hard, and some companies may have an easier pathway to get there than others,” he said.
For example, a producer whose portfolio contains multiple removable components may have considerably more opportunity to reduce plastic than a company whose product depends on a flexible plastic package for protection and distribution. That disparity is one reason the system was designed to allow producers to contribute in different ways.
Individual source-reduction plans will still play an important role. Linnea Whitney Skierski, deputy director of policy development and analysis at CalRecycle, explained that those plans will go to CAA rather than directly to CalRecycle and will inform the organization’s collective strategy. Data reported to the agency will be anonymized.
“Nobody is going to be held specifically accountable to meeting certain source reduction requirements,” Whitney Skierski said. “You’re supposed to work together as a team to identify the best opportunities that would work for you.”
CAA plans to use incentives rather than assign individual source-reduction targets to producers. Dave Lefebvre, CAA policy advisor and principal of Lefebvre Consulting Inc., said CAA expects to adjust those incentives as it receives producer feedback and individual source-reduction plans, giving the organization more information about the costs and feasibility of different reduction strategies.
The timeline, however, is tight, particularly with the first source-reduction target taking effect in 2027. That leaves producers with limited time to identify opportunities, make packaging changes, and begin contributing to the collective reduction goals.
CAA’s incentive model is being structured to recognize different levels of progress. Lefebvre described a tiered approach designed first to encourage producers to get below their 2026 supply levels and then to provide stronger incentives for reductions beyond that point. CAA also has been examining the relative costs and timing associated with pathways including lightweighting, material substitution, and reuse.
From elimination to reuse and PCR
Some of the first opportunities for may lie outside the primary package. Whitney Skierski pointed to secondary and tertiary packaging as potential areas for source reduction, particularly because changes to those materials may have little or no effect on the consumer experience.
Direct elimination could offer another path. Brandon cited examples including removing overwrap, eliminating plastic windows from cartons, right-sizing packages, and reducing packaging around products that may not require it.
“There’s a ton of different options and creative ways to sell and market that have less single-use plastics in it,” she said.
Reuse and refill offer additional opportunities, although they present a different set of challenges. Ellie Moss, executive director of Perpetual, a nonprofit focused on reuse, said the strongest opportunities identified through the needs assessment were not necessarily consumer-facing systems. Business-to-business transport packaging, reusable bulk containers, foodservice back-of-house packaging, and contained environments could offer opportunities to reduce both components and tonnage while limiting the behavior changes required of consumers.
Perpetual is also helping develop an open-loop reusable foodserviceware system in Hilo, Hawaii. The packaging includes stainless steel cups and trays, some with plastic lids, designed to circulate through a reuse system rather than be discarded after a single use. Moss said projects in contained settings can also help build the washing, collection, and other infrastructure needed to support broader consumer-facing reuse systems over time.
For some reuse models, the changes may extend beyond the package itself to how products move through the supply chain. “You actually need to rethink how you’re going to get product to market,” Moss said.
One example discussed was distributed prefill, in which products could be shipped in reusable bulk packaging to regional filling locations. Consumer-facing reusable packages could then circulate within a local market rather than traveling back and forth across the country.
PCR provides yet another pathway, although the panel cautioned against viewing it as an immediate solution to the early targets. Brandon described recycled content as an important tool for reducing virgin plastic use and supporting recycling markets, while distinguishing those benefits from physically reducing the amount of packaging placed into the market.
Lefebvre said CAA wants producers to maximize PCR use and plans to incentivize it, but incorporating more recycled content can require considerable time. “There’s a bit of a myth that PCR is going to be the savior for the first couple of targets,” he said. “It’s going to take producers time to change the way their packaging is made. They’re going to have to change the equipment that they use if they dramatically increase the PCR they’re using.”
Packaging changes bring tradeoffs
Choosing among these pathways will require producers to weigh more than plastic reduction alone. Material substitution, for example, may reduce plastic use while increasing package weight or greenhouse gas impacts.
Lefebvre said producers will need to consider environmental performance, cost, consumer expectations, and package functionality together rather than optimize around a single metric “Companies need to think about everything holistically,” he said. “It’s not just about plastic, it’s not just about GHGs, it’s not just about the consumer.”
That complexity is particularly significant for consumer brands, where packaging changes can affect much more than material use. “We also appreciate that for most companies, the package is the brand,” Lefebvre said. “So making changes to your packaging is scary.”
CalRecycle, meanwhile, expects the process to evolve as the industry learns which approaches work. Whitney Skierski emphasized that the agency wants to see measurable progress while allowing room to adjust strategies that prove ineffective.
“Success looks like active participation from the PRO and from producers in identifying where progress can be made and what that short-term progress will look like,” she said. “We want to see things improving, not see projections just for 10, 15, 30 years down the road.”
For producers, that puts the emphasis on identifying credible reductions now while continuing to develop longer-term options such as reuse and refill. The range of pathways may provide flexibility, but the discussion made equally clear that waiting for a single solution to emerge could leave companies with too little time to act.
Lefebvre said he is already hearing from producers that packaging changes are underway and from suppliers that they are considering how they can support those changes. “The journey has started,” he said. “Success is already underway. We’re having the conversation and more than having a conversation, I’m hearing that actions are taking place.” PW
