California’s source reduction plans were due Aug. 1, but according to rePurpose Global’s Alyssa Dizon, the filing deadline was the easy part. What happens over the next six years is where producers should be paying attention.
Dizon, head of product at rePurpose Global, spoke with Resource Recycling about what’s driving the crunch behind source reduction plans, why the 25% reduction target is being widely misread and why she expects the compliance burden to get harder as California’s program matures through 2032.
rePurpose Global builds software that automates packaging EPR compliance for producers. Dizon’s team also runs the company’s regulatory and sustainability intelligence unit, which tracks legislative and rulemaking activity across every state EPR program and feeds it into the platform.
A five-year plan
Source reduction plans mark the first time a packaging EPR program has asked producers to project forward rather than report backward, Dizon said.
“This is the first time that they’re being required to think about what their packaging will look like in the coming years, and project the impact of those changes to their plastic contributions in California,” she said.
That shift landed on top of an already difficult May supply-reporting deadline, leaving producers just 60 days to turn around a five-year forecast. Dizon said this requires mapping packaging changes against five separate reduction pathways while digesting guidance that kept shifting underneath them.
“They are definitely scrambling,” she said. “CAA just launched — or just announced — new guidance last week, just two weeks before the source reduction plans are due.”
The most persistent confusion Dizon sees isn’t about methodology, but rather what the law actually requires of any single company.
“The most common misconception is that the 25% reduction is an individual producer requirement,” she said.
SB 54’s reduction target applies collectively across CAA’s entire producer base, not to each company’s own packaging.
“The source reduction planning exercise is really a data collection process for CAA to get a forecast, essentially, from all producers of what they think is realistic, given the current draft incentives and draft fees and constraints on supply chain.”
Producers who believe they must show 25% reduction on paper to keep selling in California, she said, are operating on a false premise.
Despite active litigation, including the federal suit brought by the National Association of Wholesaler-Distributors and a separate suit from Oceana, NRDC and Californians Against Waste, Dizon said producers aren’t slowing down or hedging.
“They’re largely moving ahead,” she said. “I think that these legal actions are expected and part of the normal legislative process, where different stakeholders have different opinions and want to shape the future of the policy, but none of that has fundamentally changed what the requirements are.”
Compounding complexities
Dizon doesn’t expect the reporting burden to ease as California’s program matures — she expects the opposite, driven by annual bonus-and-malus recalibration and a growing, unharmonized patchwork of state programs.
“I think that the complexity will get harder,” she said. “More states are coming on board and they are not harmonized. On the source reduction front specifically for California, this initial plan… is just the tip of the spear. There is an annual progress report in California every year through the 2032 reporting cycle… the bonuses and maluses themselves are what are going to actually drive behavior, and the bonuses and maluses themselves will change.”
Her advice to producers is to sequence packaging changes by certainty — executing low-hanging fruit immediately while running parallel R&D tracks for changes that depend on future material availability or pricing.
Dizon pushed back on the assumption that meeting SB 54 automatically prepares producers for other state programs, including newer ones in Illinois and Maryland.
“California is the most different,” she said. “Colorado and Oregon are a lot more similar, and California is different than both of them… California has 95 reporting categories, whereas Colorado only had 60.”
Other states rely on voluntary eco-modulation bonuses rather than California’s mandatory source reduction mandate, she noted, and deadlines vary in ways producers can miss. Maine’s supply reports, for instance, aren’t due until later this year and a date hadn’t yet been announced, unlike the May 31 deadline most other states shared.
She also flagged a common misread of California’s fee schedule. The early fees the state charged to fund program startup are lower than what producers should expect to pay annually going forward.
“The early fees are significantly lower than your regular annual fees,” she said. “They just need startup costs funded for the program in California. Not all the states are doing that.”
Dizon closed by framing the source reduction plan as a starting point rather than a compliance finish line.
“This plan is a one-time exercise, tip of the spear,” she said. “It’s meant to catalyze forecasting, and it’s meant to help you as a producer, gather your team internally to really look around the corner, see what’s coming and make smart decisions.”
Executing on source reduction and responding to California’s evolving fee incentives, she said, “is going to be a multi-year, ongoing iterative project. So, the plan is just the beginning.”
