CalRecycle confirmed that its baseline calculations for the amount of plastic sold in the state — from which producers’ source reduction under extended producer responsibility law SB 54 will be measured — is expected to increase in the next year.
“The intent is not to just leave the baseline at this current number, which does not represent all participant producers,” said Laura Moreno, environmental program manager in CalRecycle’s policy office, at a meeting of the SB 54 advisory board on Friday.
This follows an update last week to the source reduction baseline that was informed by 2023 data shared by producers in 2026. The updated figure reflected significantly lower overall tonnage than CalRecycle previously modeled, dropping from an estimate of 2.9 million tons to 1.03 million tons. At the same time, the number of individual plastic components rose from an estimate of 171.4 billion to 222 billion.
Representatives from CalRecycle explained at the Friday meeting that the updated number reflects data from 2,127 producers, which CalRecycle estimates to only be around half of producers. Circular Action Alliance, the producer responsibility organization helping to implement the state’s EPR program, says there are now more than 4,000 producers registered in California.
The regulator did not adjust the baseline figures to account for the large swath of missing data. “While this updated baseline does reflect the best available information, CalRecycle acknowledges that not all producers reported, and not all producers submitted accurate reporting,” Moreno said.
It’s not that half of all producers necessarily skipped reporting this year; in some cases, producers submitted tonnage, but CalRecycle flagged that they obviously undercounted the number of plastic components, said Karen Kayfetz, CalRecycle’s branch chief for product stewardship.
CAA Chief of Staff Shane Buckingham noted that producers are still learning how to properly report. In addition to detailing tonnage of plastic sold or distributed in the state, they must also count individual plastic components, an aspect that seems to be especially confusing.
“That's taken a lot of work from our team to make sure that we can get reports corrected,” he said. “We're going to continue to follow up with producers and make sure that we get in all that data.”
Corrections coming
CalRecycle anticipates having a corrected baseline value a year from now. A higher baseline would ultimately mean producers would have to cut more plastic weight to meet the percentage-based source reduction thresholds.
“CalRecycle will issue a November 2027 source reduction baseline correction before assessing and reviewing compliance with the source reduction targets in SB 54,” Moreno said, which include that producers collectively achieve 25% source reduction from the baseline come 2032.
Producers that are not currently included in the baseline calculation will need to provide new or corrected data by July 2027 for consideration. “We’ll be moving forward very quickly to continue to engage with CAA and producers,” Moreno said.
This includes plans to update existing guidance on source reduction reporting “in the shorter term,” Moreno said.
CalRecycle is taking “a compliance assistance approach,” Kayfetz said. “So really reaching out and having those clarifying conversations, understanding where the misreporting is coming from, providing additional guidance and information, and doing so in close collaboration with the PRO so that that producer community has the information necessary and the support necessary to provide us with accurate information for our next update.”
Kayfetz also said CalRecycle expects that once producers better understand guidance or interact more with the program, some will instigate their own checks and their own corrections.
“Our priority is to provide compliance assistance first, but not forever,” Kayfetz said.
