California SB 54 created an extended producer responsibility program for single-use packaging and single-use plastic food service ware. In plain English: producers are being asked to take more responsibility for the packaging they put into the market, including how much plastic they use, whether packaging can be recycled or composted, and how the system gets funded.

California goes further than other states' EPR laws. Every packaging EPR law asks producers to register, report packaging data, and pay fees based on weight and material type. California also requires mandatory plastic source reduction. That means brands need to change what they use, not just account for it.

The law also has major packaging targets. By 2032, California’s program is designed to cut single-use plastic packaging and food service ware by 25%, recycle 65% of single-use plastic packaging and food service ware, and ensure 100% of single-use packaging and plastic food service ware is recyclable or compostable.

For source reduction planning, CalRecycle guidance focuses on two core metrics: the weight of plastic covered material and the number of plastic components sold, offered for sale, or distributed in California. That means brands need to understand not just “Do we use plastic?” but “Where exactly is the plastic, how much does it weigh, and how many separate plastic components are involved?”

The Individual Source Reduction Plan (ISR) is the formal forward-looking roadmap due August 3, 2026. It should outline how your brand intends to achieve the 10% reduction by 2027 and the 25% reduction by 2032 versus your 2023 baseline. It should also show which reduction pathways you plan to use, which SKUs are affected, and how your plastic weight is expected to decline year by year. At least 2% of your total reduction must come from reuse or refill systems.

So yes, the ISR is a compliance filing. But beyond the filing itself, a well-built plastic reduction roadmap is also a practical business tool. It helps you decide which packaging changes to make first, which ones need more testing, which ones have the biggest operational tradeoffs, and which ones can reduce both plastic and future EPR fee exposure.

Start by assigning an owner. Not a committee. An owner.

SB 54 touches sustainability, operations, procurement, legal, finance, ecommerce, product, and marketing. But someone needs to drive the packaging action plan, gather data, push decisions forward, and keep the August 3 deadline from turning into a giant shared spreadsheet that everyone opens and no one finishes.

Your first job is to create the working list. Pull every packaging format your brand currently uses for products sold into California. Include the obvious stuff, like mailers, boxes, pouches, bags, labels, and tape. Then include the less obvious stuff, like product sleeves, plastic windows, hang tabs, zipper closures, inner bags, shrink wrap, void fill, pallet wrap, kitting materials, return packaging, sample packaging, and promotional inserts with coatings or laminations.

SB 54-covered material may include single-use packaging used for the containment, protection, handling, delivery, or presentation of goods. Packaging can include primary, secondary, and tertiary packaging. So, stopping at the outer mailer is not enough.

Where should you begin? Start with your highest-volume plastic packaging components and the lowest-disruption reduction opportunities. Eliminating and substituting materials on your top one or two plastic components will almost always move your plan forward faster than spreading effort across dozens of small changes.

Your suppliers should be able to help you understand what your packaging is made from. If they can’t, that is useful information, too.

For each packaging component, request:

• Bill of materials or material composition

• Total item weight

• Plastic-only weight, where applicable

• Resin type or plastic category

• Recycled content percentage

• Post-consumer recycled content percentage, if applicable

• Recyclability information

• Compostability information, if applicable

• Certifications, such as FSC, SFI, RCS, or compostability certifications

• Ink, adhesive, coating, lining, or lamination details

• Country of manufacture

• Minimum order quantities

• Lead times

• Alternative formats they can produce

Ask for data in a usable format. PDFs are fine for backup documentation. Spreadsheets are better for actual planning.

Your internal team should also add operational data. Which packaging formats slow down pack-out? Which ones cause damage? Which ones create customer complaints? Which ones require too much void fill? Which ones are oversized? Which ones are used across your highest-volume SKUs?

Compliance is the forcing function. Better packaging is the win.

Once your packaging dataset is underway, sort your data three ways.

First, sort by total plastic weight. This helps you find the packaging formats contributing the most plastic by mass.

Second, sort by number of plastic components. SB 54 source-reduction progress is measured by both plastic weight and the number of plastic components, so a lightweight component can still matter if it shows up in many units.

Third, sort by volume. A packaging format used on your bestselling SKU may matter more than a heavier material used occasionally.

Then create a short list of plastic-heavy or plastic-complicated packaging. Look for:

• Poly mailers used across high-volume ecommerce shipments

• Bubble mailers with plastic cushioning

• Plastic air pillows

• Plastic void fill

• Plastic tape

• Polybags

• Shrink wrap

• Stand-up pouches with multilayer plastic structures

• Plastic windows on otherwise paper packaging

• Plastic labels or stickers

• Plastic coatings, barriers, or laminations

• Plastic zipper closures

• Plastic hang tabs, hooks, handles, or seals

Tiny pieces can add up. Especially when they ride along with every order.

“Risky” does not always mean “noncompliant.” It means the material deserves attention before you build your plastic packaging reduction plan around it.

Flag packaging that falls into one or more of these categories:

Plastic-heavy: These are formats where plastic is the main material, like poly mailers, plastic bubble mailers, polybags, shrink wrap, and plastic void fill.

Multi-material: These are harder to understand, harder to report, and often harder for customers to dispose of properly. Think paper with plastic windows, laminated pouches, coated paperboard, or packaging with mixed layers.

Hard to recycle: Flexible plastic, multilayer films, and plastic-coated formats can be more complicated than straightforward paper-based packaging.

Unnecessary: This is the best category. Why? Because elimination is the cleanest packaging swap. Extra sleeves, inner bags, inserts, wraps, duplicate labels, or oversized void fill may be removable without changing the product experience much at all.

Customer-confusing: If your customer has to ask, “Is this recyclable?” the package may be doing too much work. Or not enough.

For SB 54 planning, source reduction is about using less covered material in the first place. Recycled content still matters—we’re big fans—but it isn’t the same as reducing plastic. To build a stronger plastic reduction plan, look for ways to use less packaging overall, reduce plastic components, right-size shipments, eliminate unnecessary materials, and shift to reusable, refillable, or nonplastic options where they make sense.

The best near-term swaps are the ones that don’t require new equipment, retraining your entire warehouse, changing your product formulation, or slowing pack-out.

Start with packaging changes that are practical, testable, and low-disruption.

Swap plastic tape for curbside recyclable paper tape

This can reduce plastic components on corrugated shipments and make the disposal story simpler for customers.

Replace plastic void fill with paper-based void fill

If the product protection profile allows it, paper void fill can be easier for customers to recycle and easier for your team to explain.

Right-size boxes and mailers

Less empty space means less material and less void fill. It can also improve the unboxing experience because the package feels intentional, not wasteful.

Move from poly mailers to recycled paper mailers where product fit allows

Apparel, soft goods, and other non-fragile products may be good candidates for paper-based mailers, depending on moisture needs, transit risk, and brand experience.

Consolidate packaging components

Can one package do the work of two? Can you remove an inner bag? Can you skip a sleeve? Can you print disposal instructions directly on the package instead of adding another insert?

Reduce or remove plastic windows

If the window is not essential to the customer experience or retail shelf function, it may be a high-visibility place to reduce plastic complexity.

Choose recycled-content plastic when plastic is still the right material

Recycled content can still reduce reliance on virgin plastic and support a stronger sustainability strategy. Just be specific about what changed, what the packaging is made from, and what claim you’re making.

Test reusable packaging where it actually fits the model

Reusable packaging can be powerful for take-back programs, rental models, repairs, returns, circular apparel, and closed-loop customer relationships. It is not automatically right for every brand. The use case matters.

Use a simple scoring system. Nothing fancy. Just honest.

Score each possible packaging swap from 1 to 5 across these factors:

• Plastic Reduction Impact

• Packaging Cost Impact

• Customer Experience Impact

• Operations Impact

• Product Design Impact

• Product Protection Impact

• EPR Fee Impact

Then prioritize changes that score high on plastic reduction and operational feasibility. Those are your first moves.

For many ecommerce brands, the best first project is not the most dramatic project. It is the packaging change that removes meaningful plastic without changing the pack-out flow. A paper tape swap. A mailer change for one high-volume SKU. A reduction in void fill. A right-sized box. A cleaner return mailer. A new inner packaging format that protects the product just as well with less plastic.

Each factor matters for a different reason. Plastic Reduction Impact tells you whether the swap helps your ISR targets. Packaging Cost Impact helps you understand the fully loaded cost, not just the unit price. Customer Experience Impact makes sure the package still feels right when it lands in someone’s hands. Operations Impact keeps fulfillment from becoming chaos. Product Design Impact flags changes that may affect the product itself, not just the package. Product Protection Impact keeps damage risk front and center. EPR Fee Impact helps you understand whether the change may reduce future fee exposure.

Once you have a few practical wins, your SB 54 packaging action plan becomes much easier to sell internally. Procurement sees supplier options. Operations sees that fulfillment still works. Marketing sees a clearer sustainability story. Finance sees that this is not a blank-check redesign. Leadership sees momentum.

That’s how packaging change gets real.

Here’s the step-by-step version. Copy it. Paste it. Assign owners.

Step 1: Assign the owner and define the scope

Name one owner. Confirm which product lines, brands, channels, and California sales pathways are in scope. Pull in sustainability, operations, procurement, legal, finance, and marketing.

Step 2: Build your packaging inventory

List every primary, secondary, and tertiary packaging component used for products sold into California. Include shipping packaging, retail packaging, inner packaging, product packaging, kitting materials, return packaging, tape, labels, void fill, and wraps.

Step 3: Request supplier data

Ask suppliers for material composition, total weight, plastic-only weight, resin type, recycled content, certifications, recyclability or compostability documentation, coatings, adhesives, inks, lead times, and available alternatives.

Step 4: Identify plastic components

Mark every component that is made partially or entirely of plastic. Don’t forget windows, coatings, labels, tape, adhesives, zipper closures, linings, and laminated layers.

Step 5: Rank SKUs and packaging formats

Sort by plastic weight, number of plastic components, and unit volume. Identify the packaging formats creating the largest plastic footprint or the most reporting complexity.

Step 6: Map reduction initiatives

For each plastic-heavy or plastic-complicated component, identify the most realistic reduction pathway. California recognizes five major pathways: elimination, lightweighting, material substitution, reuse or refill, and concentration or bulk formats.

Start with the highest-volume plastic SKUs and the lowest-disruption pathways. Lightweighting can be fast, but it may not move the needle enough on its own. Material substitution can be more impactful, but it needs product protection and customer experience testing. Reuse, refill, concentration, and elimination can be powerful, but they need to make sense for your business model. 

Step 7: Match swaps to operational reality

Look for lower-disruption changes first: right-sizing, paper tape, paper void fill, recycled paper mailers, reduced inner packaging, plastic window removal, and recycled-content options where plastic remains necessary.

Step 8: Order samples and run pack tests

Test fit, protection, pack speed, label adhesion, seal strength, customer presentation, storage needs, and disposal messaging. A sustainable package that fails in fulfillment is not a sustainable win.

Step 9: Build your plastic packaging reduction plan

Document your current packaging baseline, top plastic reduction opportunities, recommended swaps, affected SKUs, expected reduction impact, owners, cost implications, risks, supplier data gaps, and year-by-year forecast. Then decide what moves now, what needs testing, and what belongs in a longer-term roadmap.

This is not the whole SB 54 journey. It is the start of a much better one.

This is exactly the kind of packaging problem we’re built for.

EcoEnclose helps brands find sustainable packaging that fits their business, brand, budget, and operations. Our role is not just to sell a mailer or a box. We help you compare options, understand tradeoffs, pressure-test claims, avoid greenwashing, and choose packaging swaps that can actually work in the real world.

For SB 54, that means we can help you:

• Audit your current packaging system

• Identify plastic-heavy formats

• Compare plastic reduction opportunities

• Evaluate paper, recycled-content, reusable, recyclable, and compostable options

• Prioritize swaps by plastic reduction impact, cost, customer experience, operations, product design, product protection, and EPR fee impact

• Review sustainability claims before they go on packaging

• Build a practical roadmap that does not disrupt fulfillment

We also created a personalized plastic-reduction tool for brands navigating California’s mandatory plastic-reduction requirements. It gives tailored recommendations, impact analysis across cost and customer experience, realistic transition considerations, and access to packaging experts when you need support.

Because the right packaging plan should do more than check a box. It should help your brand move faster, reduce risk, and make a sustainability improvement your customers can actually see.

What is an Individual Source Reduction Plan?

An Individual Source Reduction Plan, or ISR, is the formal forward-looking roadmap California requires producers to submit for SB 54 source reduction planning. It outlines how your brand plans to reduce plastic packaging against your 2023 baseline, including which pathways you’ll use, which SKUs are affected, and how your plastic weight is expected to decline over time.

What packaging data do brands need for SB 54 source reduction planning?

Brands should gather data on both the weight of plastic-covered material and the number of plastic components. CalRecycle guidance says source reduction reporting uses both metrics and that plastic weight calculations should include only the plastic portion of a covered material.

Does switching to recycled plastic count as source reduction?

Not by itself. Recycled content is still a meaningful sustainability improvement, especially when plastic remains the best packaging option for performance, protection, or operations. But if your goal is plastic reduction, look for ways to use less plastic overall.

What are the fastest packaging swaps for SB 54 planning?

Fast swaps often include paper tape, paper void fill, right-sized boxes, recycled paper mailers, fewer inner packaging components, plastic window removal, and reduced plastic cushioning. The best first move depends on your product, fulfillment process, customer experience, and current packaging footprint.

Should my brand eliminate all plastic packaging?

Not necessarily. The goal is to reduce unnecessary plastic and choose better packaging systems. Sometimes paper, reusable, refillable, or recyclable formats are the right move. Sometimes recycled-content plastic may still be needed for durability, moisture protection, or product integrity. The key is to make a specific, data-backed decision.

Can EcoEnclose help us build an SB 54 packaging compliance checklist?

Yes. We can help you organize your packaging data, identify plastic-heavy SKUs, evaluate sustainable packaging alternatives, review packaging claims, and prioritize swaps that fit your fulfillment reality. Start with our California SB 54 resource hub, or connect with our team for packaging-specific support.

SB 54 can feel overwhelming because it asks brands to look at packaging from every angle at once: data, compliance, sustainability, cost, operations, product design, product protection, and customer experience.

But your next move can be simple.

Confirm your baseline. Find the plastic. Get the data. Flag the risky stuff. Prioritize the swaps that can happen without chaos. Then build from there.

We’re here to help you turn SB 54 from a compliance scramble into a practical packaging roadmap. Work with EcoEnclose on your custom packaging and plastic reduction journey, and we’ll help you find the right next move for your brand, your budget, and your fulfillment team.