CalRecycle Cuts SB 54 Plastic Baseline to 1.03 Million Tons

CalRecycle on Monday published a revised source reduction baseline of 1.03 million tons of plastic covered material sold or distributed in California in 2023 — a figure 64% lower than the agency's previous estimate of 2.9 million tons, and one that directly determines how much plastic producers must eliminate under SB 54.

The updated report, a cornerstone document in the state's extended producer responsibility program for packaging, also counts 222 billion plastic components entering the California market in 2023. That component count rose from an earlier estimate of 171.4 billion, even as the tonnage fell sharply.

The numbers matter because they set the denominator for the law's binding targets. By 2032, producers must collectively achieve 25% source reduction against the 2023 baseline, with interim milestones of 10% by 2027 and 20% by 2030. A lower starting tonnage translates into fewer tons of plastic that must leave the system.

Where the new number comes from

CalRecycle first issued its Source Reduction Baseline Report on December 31, 2024, estimating the weight of plastic and the number of plastic components tied to covered material sold, offered for sale or distributed in the state during 2023. Monday's revision rests on calculations by Circular Action Alliance, the producer responsibility organization implementing the program, which solicited company-level data from registered producers earlier this year.

"The updated source baseline includes data from 2,127 producers of plastic covered material, accounting for about 50% of total participant producers," CalRecycle said. The agency cautioned that "not all producers have submitted accurate data" and that producers whose figures are not yet reflected "will be included in a future correction."

Individual source reduction plans were reviewed by CAA but never submitted individually to CalRecycle. In those documents, producers were also required to outline source reduction already achieved over the previous decade — a self-reported record that now sits underneath the state's official baseline.

What does a lower baseline change for the program?

Researchers at the Benioff Ocean Science Laboratory at UC Santa Barbara raised alarms before the update landed. The group compared preliminary producer estimates against landfill characterization studies and wrote to CalRecycle with concerns that the self-reported data understated the true scale of plastic in the waste stream.

The update "has consequences beyond accounting," Alex Fox, communications specialist with the lab, said in an email sent before CalRecycle released the revised figures. "A baseline that starts too low shrinks the amount of plastic producers must eliminate."

After reviewing the updated report, Fox said the group was "surprised to see the mass for the updated baseline number go down and the number of items go up." The divergence — fewer tons, more components — suggests lighter and smaller packaging formats are proliferating even as aggregate weight declines, a pattern that complicates both measurement and reduction strategy.

How producers can hit the targets

SB 54 defines several allowable pathways toward the reduction obligations. Producers may:

• Implement reusable or refillable alternatives, which must deliver 10% of source reduction by 2032;
• Eliminate unnecessary plastic from packaging and products;
• Swap in non-plastic alternative materials;
• Rightsize or lightweight packaging.

The law also permits up to 8% of the source reduction requirement in any given year to come from the use of postconsumer recycled plastic, giving producers partial credit for recycled-content uptake alongside outright elimination.

The revised baseline reweights that toolkit in practical terms. With the obligation now calculated against 1.03 million tons rather than 2.9 million tons, the absolute tonnage that must disappear by 2032 falls by roughly 470,000 tons — a reduction in required effort that critics argue shifts the burden from producers to the environment.

What happens next

Two clocks are now running. CalRecycle's SB 54 advisory board meets Friday to discuss CAA's revised program plan for packaging EPR in California. The agency has 75 calendar days from CAA's October 13 submission to decide whether to approve that plan, giving it until late December to rule on the operational blueprint for the entire program.

Further baseline revisions are also in play. Because half of participating producers have yet to submit complete data, and CalRecycle has flagged inaccurate submissions, the 1.03-million-ton figure remains provisional. Each future correction will reset the arithmetic on the 2027, 2030 and 2032 targets — and with them, the volume of plastic California's producers must actually remove from the market.