A Practical Guide to California’s Individual Source Reduction Plan (ISRP) for Producers

California’s Individual Source Reduction Plan (ISRP) requirements can feel heavy at first, but the structure is more straightforward than it looks. At a high level, you are connecting three things: where you started, what has happened so far, and how you plan to reduce plastic over time.

Once you understand how those pieces fit together, the reporting becomes much easier to navigate.

It Starts With Your 2023 Baseline

Most producers have already engaged with this process through the early data submission in late 2025, which captured 2023 packaging data. That dataset is now your baseline year. Every reduction you report moving forward is measured against it.

However, this is not a “set it and forget it” number. Before submitting your ISRP, you will need to revisit that data and either reconfirm it or update and resubmit it if better information is available. This matters more than anything else - if your baseline shifts, your entire reduction trajectory shifts with it.

Three 2026 Reports - Baseline, Supply, ISRP

In 2026, producers will have three key submissions: their 2025 supply data report, the Annual Source Reduction Report, and the Individual Source Reduction Plan (ISRP).

The Annual Source Reduction Report, due May 31, 2026, functions much like a standard annual report. It uses 2025 data to show what has happened so far and whether you are trending in the right direction against your 2023 baseline. At this stage, these reductions do not carry legislative weight - they act as a goalpost.

The Individual Source Reduction Plan (ISRP), due no later than August 1, 2026, is your first real milestone. It sets out how you intend to meet California’s reduction targets and becomes the reference point for future performance.

The first formal progress against this plan will be reflected in your May 31, 2027 reporting cycle, when 2026 data is assessed against the 2027 target. While this is framed as progress toward 2027, the calculation still measures your total plastic against your 2023 baseline - showing whether you are moving toward that target in real terms.

	Legislated target years
	2027	2030	2032
Source reduction targets	10%	20%	25%
Reuse, refill (all target years)* and elimination (2032 target year only)	2% minimum	4% minimum	10% minimum
Reuse/refill investments	Amount to be determined by PRO, informed by CalRecycle needs assessment

*The reuse and refill targets are not separate from the overall reduction requirement - they contribute toward it, but are also independently required. Producers cannot meet their total reduction targets through design changes alone; a defined portion of progress must come from reuse and refill systems.

How Reduction Is Measured (And Why Growth Matters)

Everything ties back to your 2023 baseline.

California is measuring whether the total amount of plastic you supply decreases over time compared to that starting point. This means reductions are assessed at a total level, not just per unit. And this is where sales growth becomes critical.

If your business grows, your packaging volumes will likely grow with it. That means your percentage reduction needs to work harder just to keep total plastic flat - and even more to actually reduce it.

The Five Source Reduction Pathways

Every reduction you report must be tied to one of California’s defined pathways. This is how regulators understand how your reductions are being achieved in practice.

• Reuse and refill

  Moving away from single-use packaging into systems designed for multiple uses, supported by real collection and reuse infrastructure.

  
  

• Elimination

  Removing packaging or components entirely, such as eliminating overwrap or unnecessary elements.

  
  

• Material switching

  Replacing plastic with another material that meets recyclability or compostability requirements.
  

• Right-sizing, lightweighting, and bulk formats

  Reducing material use through design changes - thinner packaging, smaller formats, concentrated products, or bulk configurations.
  

• Post-consumer recycled (PCR) content

  PCR reduces reliance on virgin plastic but plays a limited role in source reduction, with its contribution capped at no more than 8% of the total plastic covered material supplied into California. This means PCR can support your reduction targets, but cannot carry them.

  
  

  To count, PCR must be verified through an approved certification. CalRecycle has designated the Association of Plastic Recyclers PCR Certification as the standard, and while alternatives may be proposed, only one certification framework can be used within a program plan. In practice, PCR should be treated as a supporting lever, not your primary strategy.

Building Your ISRP

Once your baseline is confirmed and your early reporting is complete, building your ISRP becomes a structured exercise.

Start with your 2023 baseline, then layer in your 2025 reported data to understand your current position. From there, map out what your packaging will look like in the key future data years - 2026, 2029, and 2031 - which align to California’s 2027, 2030, and 2032 targets.

The real work is translating planned changes into measurable impact. Every packaging decision needs to show up in the numbers, whether it’s reducing material, removing a component, or shifting formats. At the same time, you need to factor in expected sales growth, since increases in volume can offset those gains.

By the end of this exercise, your plan should clearly show one thing: how your total plastic footprint changes over time compared to 2023 - and whether it is actually going down.

Incentives Are Coming

An additional layer producers should be aware of is the upcoming incentive structure.

Circular Action Alliance has indicated that a bonus and malus system will be introduced, where producers that exceed expectations may benefit financially, and those that fall short may face penalties. More detail is expected shortly.

This reinforces that the program is moving beyond reporting toward performance.

Final Thought

The easiest way to think about ISRP is as a sequence.

Your 2023 data defines where you started.

Your 2025 data shows where you are trending.

Your ISRP sets the path forward.

If those three pieces align - and are backed by high-quality, defensible data - the process becomes far more manageable, and far more defensible.