SB 54 Source Reduction: What “Using Less Packaging” Actually Means for Brands
Posted By on Jul 29th 2026
SB 54 Source Reduction: What “Using Less Packaging” Actually Means for Brands
California SB 54 asks brands to do more than register, report packaging data, and pay EPR fees. It requires producers to reduce the plastic packaging they put into the market. That sounds simple: use less packaging.
In practice, the right changes depend on what you sell, how you fulfill orders, how your products are protected, and which components account for the most plastic. A lightweight shipping mailer presents different opportunities than a rigid bottle, a multilayer pouch, or a product packed with several protective components. Effective SB 54 source reduction starts with a packaging audit that identifies opportunities to remove material, reduce weight, improve fit, or shift to a more circular model without increasing damage, slowing fulfillment, or weakening the customer experience.
Key Takeaways
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SB 54 requires brands to reduce the total weight of plastic packaging they put into the California market, not simply improve recyclability or increase recycled content.
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Start your packaging audit with your highest-volume plastic components, since changes there typically create the largest reductions.
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Removing unnecessary components and right-sizing packaging can reduce packaging waste without changing your core product.
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Lightweight packaging can be a relatively low-disruption improvement, but every new format still needs performance testing.
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Reusable packaging and take-back packaging can support source reduction when the return system works operationally.
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Recycled content supports a sustainable packaging strategy, but replacing virgin plastic with recycled plastic does not automatically count as source reduction.
Table of Contents
- What Does SB 54 Source Reduction Require?
- Where Should Your Packaging Audit Begin?
- Can You Eliminate a Packaging Component?
- Can You Switch to a Lighter-Weight Format?
- Is Your Packaging Bigger Than It Needs to Be?
- Can You Remove a Layer Without Increasing Damage?
- Could Reusable or Take-Back Packaging Work?
- Could Concentration or Bulk Formats Reduce Packaging?
- Should You Replace Virgin Plastic?
- How Should You Prioritize Packaging Changes?
- Build a Packaging System That Uses Less
- Frequently Asked Questions
What Does SB 54 Source Reduction Require?
According to CalRecycle, SB 54 established California’s extended producer responsibility program for single-use packaging and plastic food service ware. Along with registration, reporting, fee, recyclability, and recycling requirements, the law requires producers to reduce plastic-covered material against a 2023 baseline, with a 10% source-reduction target by 2027 and a 25% target by 2032. At least 2% of the 2027 reduction must come from shifting to reusable or refillable formats.
This is what makes California SB 54 compliance different from standard EPR packaging compliance. Paying a fee does not replace the need to reduce plastic packaging.
Source reduction can include:
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Eliminating plastic packaging components
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Reducing the weight of a plastic component
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Moving from plastic to a non-plastic format
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Replacing single-use packaging with reuse or refill systems
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Reducing packaging through concentration, bulk formats, or better sizing
The important word is reduce. Better recyclability and higher recycled content both matter, but neither replaces the requirement to lower the total amount of plastic packaging entering the market.
Where Should Your Packaging Audit Begin?
Do not start by debating every package your company uses. Start with the data. Build a component-level inventory of your packaging. That means treating each separate piece as its own line item rather than recording an entire shipment as “one package.”
For example, an ecommerce order might include:
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An outer poly mailer
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An inner product bag
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A plastic garment fastener
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A return mailer
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A promotional sample in a small plastic pouch
Record the material, weight per unit, annual volume, dimensions, purpose, and whether the component contains plastic. Then calculate the total annual plastic weight associated with each component.
Your packaging audit should identify the biggest opportunities for reduction while capturing the operational context for each component. Ask:
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What job does this component perform?
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What happens if we remove or change it?
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Is it required for protection, shelf life, tamper evidence, fulfillment, or returns?
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Is it used for every order or only certain SKUs?
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Can we test a lower-material option without changing the product?
The answers help separate realistic packaging source-reduction opportunities from those that look good in a spreadsheet but fail during fulfillment.
Can You Eliminate a Packaging Component?
Reducing the component count is often the cleanest source-reduction move because the eliminated component no longer contributes to plastic weight.
Look for pieces that entered your packaging system one at a time. An extra bag may have been added after a contamination complaint. A shrink band may have been introduced for merchandising. A plastic insert may remain even though the product design has changed.
Review the full packaging sequence and ask whether each piece still has a necessary job. Potential opportunities include:
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Removing unnecessary inner poly bags
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Eliminating plastic windows from paperboard packaging
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Dropping redundant overwrap or secondary sleeves
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Removing plastic hang tags, fasteners, or promotional components
Do not assume that “secondary” means unnecessary. Food, beauty, wellness, and other sensitive products may need barriers or tamper-evident features. The right question is not whether a component looks excessive. It depends on whether you can remove it while maintaining product integrity and meeting applicable requirements.
Validate the change under actual shipping, storage, and fulfillment conditions. A component is only redundant if the package still works without it.
Can You Switch to a Lighter-Weight Format?
Lightweight packaging reduces the amount of material used in each unit while preserving the package’s basic function.
For flexible packaging, this may mean using a thinner film. For rigid containers, it may mean reducing wall thickness. For a pouch, it could mean reducing unnecessary headspace or redesigning the dimensions so less material is required.
Because the format may stay familiar to fulfillment teams and customers, lightweighting can be less disruptive than a complete material change. It can also add up quickly across a high-volume packaging SKU. But thinner is not automatically better.
A mailer that tears during fulfillment, a pouch that loses barrier performance, or a bottle that deforms during transit can create more waste through damaged products and reshipments. Lightweight packaging needs to pass the same core tests as the current format.
Evaluate:
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Seal and seam strength
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Puncture and tear resistance
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Compression performance
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Moisture and oxygen barriers, when relevant
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Performance across temperature changes
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Compatibility with packing equipment
Custom shipping boxes made with recycled content. Source: EcoEnclose
Is Your Packaging Bigger Than It Needs to Be?
Right-size packaging fits the product closely enough to protect it without carrying unnecessary material or empty space.
Oversized packaging creates several forms of waste. The outer package uses more material. The empty space may require extra void fill. The shipment can take up more room in storage and transportation. It may also leave customers wondering why a small product arrived in a large box.
Review product dimensions, not just the sizes you currently stock. Many brands rely on a limited packaging assortment and place products into whichever available format is close enough. Over time, that convenience can create a large gap between the package and the product.
Look for:
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Mailers with excess length or width
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Boxes that routinely need large amounts of void fill
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Pouches with more headspace than the product requires
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One standard package being used across very different SKUs
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Subscription shipments that could use a better-fit recurring format
Right-size packaging does not require a unique box or mailer for every product. Too many sizes can complicate inventory and packing. The better approach is to analyze your order mix and identify a small set of sizes that fit the largest share of orders efficiently.
Evaluate new sizes at the packing station before rolling them out. A theoretically perfect package may be too slow to load, difficult to seal, or unforgiving when an order includes an extra item.
Can You Remove a Layer Without Increasing Damage?
Layers can accumulate for understandable reasons. A brand wants better presentation, extra protection, a moisture barrier, or a cleaner return experience. The result may be a product inside a bag, wrapped in tissue, placed in an inner box, and shipped in an outer mailer.
Review each layer separately. Ask what function it serves and whether another part of the packaging system already performs the same function. A stronger right-sized outer package may reduce the need for interior cushioning. A paper band may hold a soft good together without a full inner poly bag. A shipping box may provide enough protection without an additional retail carton for direct-to-consumer orders.
Reducing layers can also simplify the customer experience. Fewer pieces mean fewer disposal decisions and less unpackaging clutter.
Do not strip away layers only to replace them with a heavier outer package. Compare the total system, including plastic weight, overall material use, protection, pack time, and end-of-life options.
Could Reusable or Take-Back Packaging Work?
Reusable packaging can reduce reliance on single-use packaging, but only when the package completes enough successful reuse cycles to justify the system around it.
A reusable mailer with no practical return path is just a more durable single-use mailer. A refill container that customers rarely refill may not deliver the intended reduction.
Take-back packaging is most promising when your business already has a reverse-logistics loop. Examples include subscription services, rental programs, repair services, resale platforms, recycling programs, and brands that regularly process customer returns.
Before launching a reusable packaging model, define:
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How the packaging gets back
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Who pays for the return
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How it is inspected and cleaned
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How many cycles it must complete
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What happens when it is damaged
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How customers receive clear instructions
Customer participation is part of the packaging design, so the return process needs to be easy, visible, and practical. Start with a contained pilot involving one customer group, region, subscription program, or product category.
Track return rates, turnaround time, loss, damage, cleaning needs, customer feedback, and actual reuse cycles before expanding the program. Reusable packaging can be a strong source-reduction strategy, but it should not be forced into a business model in which package recovery is unlikely.
Could Concentration or Bulk Formats Reduce Packaging?
Concentration and bulk formats can reduce the amount of packaging needed to deliver the same quantity of product. This approach can work well for products such as cleaning solutions, personal care items, supplements, and other consumables where a smaller concentrate, larger refill, or multi-use format can replace several individually packaged units.
Examples include concentrated formulas that use smaller containers, refill systems that keep the primary package in use longer, and bulk or multi-unit formats that reduce packaging per ounce or serving. These approaches can create meaningful source reduction, but they often require product reformulation, updated customer instructions, or changes to fulfillment and merchandising.
Before moving forward, confirm that the format is convenient, easy to understand, and realistic for how your customers use the product. A concentrated or bulk format only delivers meaningful source reduction when customers adopt it, and the overall system continues to protect the product throughout its life cycle.
Should You Replace Virgin Plastic?
Replacing virgin plastic with post-consumer recycled content can reduce demand for new plastic and strengthen your sustainable packaging strategy. But recycled content and SB 54 source reduction are not the same. A 10-gram mailer still contains 10 grams of plastic, whether it is made with virgin or recycled resin. To support source reduction, pair recycled content with a change that lowers plastic weight or component count, such as moving to a thinner mailer, reducing package size, or eliminating an unnecessary layer.
Switching to a non-plastic material may reduce plastic more directly, but it still requires a full-system review. Paper, molded fiber, aluminum, glass, and other formats can differ in weight, cost, protection, recyclability, fulfillment requirements, and customer experience. The right option is the one that reduces plastic while still working for your product, operations, brand, and customers.
How Should You Prioritize Packaging Changes?
A long list of packaging ideas is not yet a reduction plan. You need to rank the opportunities. Score each possible change based on:
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Expected plastic weight and component reduction
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Product protection risk
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Operational effort
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Cost and inventory impact
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Customer experience
Start with high-volume components and changes that create meaningful reductions with manageable disruption. Removing an unnecessary bag, right-sizing a common mailer, or reducing film thickness may move faster than redesigning a product around a refill system.
More structural initiatives can follow. Material substitution, reusable packaging, and product concentration may deliver larger reductions, but they often require more development, testing, capital, and customer education.
Set a clear owner and timeline for each initiative. Record the current package, proposed package, affected SKUs, expected reduction, testing requirements, launch date, and actual results after implementation.
A practical roadmap turns California SB 54 compliance into an ongoing packaging management process instead of a one-time scramble.
Build a Packaging System That Uses Less
Using less plastic is not about making random packaging cuts. It starts with understanding your baseline, identifying the components that matter most, and sequencing changes your products and operations can support.
We can help you evaluate your current packaging, compare source-reduction pathways, and develop a practical roadmap for upcoming SB 54 targets. Connect with our team for hands-on support in developing your source reduction plan.
Frequently Asked Questions
What if reducing packaging increases product damage?
Do not implement the change at full scale. Adjust the design, test another format, or prioritize a different component. Product loss and reshipping can undermine both the operational and environmental value of a packaging reduction. Protection remains a core packaging requirement.
How should a growing brand plan around an absolute reduction target?
Model future sales volume alongside the planned packaging changes. A lighter package may reduce plastic per order while total plastic use continues to rise as the business grows. Your roadmap needs to forecast total plastic weight, not only improvement per unit.
Can one packaging change support more than one reduction lever?
Yes. A brand might replace an oversized virgin-plastic mailer with a smaller, thinner recycled-content mailer. That project combines right-sizing, lightweighting, and less virgin plastic. Track each source-reduction effect carefully so the same reduction is not counted twice.
How do we evaluate packaging used by a 3PL?
Confirm who selects, purchases, and directs the use of the packaging. Then request component-level specifications, including material, unit weight, annual volume, recycled content, and dimensions. Your legal team should verify your company’s producer obligations rather than assuming the 3PL is responsible.
About EcoEnclose
EcoEnclose is a sustainable packaging provider helping brands optimize packaging choices to align with EPR laws—reducing fees, minimizing plastic use, and building smarter long-term strategies.