California’s SB 54 (the Plastic Pollution Prevention and Packaging Producer Responsibility Act) measures producers’ source-reduction progress against a 2023 baseline: how much plastic covered material was sold, offered for sale, or distributed into California during calendar year 2023. Under 14 CCR § 18980.9, that baseline covers only plastic covered material, tracked two ways: by the weight of the plastic and by the number of plastic components. It does not total all of your packaging, even though your broader annual reporting to the Circular Action Alliance (CAA) covers other material types too. If your team wasn’t tracking packaging data by material type and by state back in 2023, pulling that figure together now can feel like reverse-engineering a report nobody knew they’d need.
This guide walks through where that 2023 plastic baseline comes from, how to reconstruct it if you don’t have it on hand, and what to do if your business didn’t exist or wasn’t obligated yet at the time.
Quick Answer
Your SB 54 2023 baseline isn’t a single lump-sum weight for all your packaging. Under 14 CCR § 18980.9, the source-reduction baseline covers plastic covered material specifically, measured two ways: the weight of plastic covered material you sold, offered for sale, or distributed into California in 2023 (counting only the plastic portion of each component, not the paper label or metal closure attached to it), and the number of plastic components across that packaging. Paper, glass, metal, and other non-plastic materials are not part of the source-reduction baseline; they’re handled through your broader annual supply reporting. You build both plastic figures by pulling 2023 sales and shipping records, attributing the California-specific share of units sold, and multiplying by the plastic weight and plastic component count per unit from your packaging specs or bills of materials. That data goes to the Circular Action Alliance (CAA), the registered producer responsibility organization, which compiles producer data and submits it to CalRecycle.
Step-by-Step: Reconstructing Your 2023 Plastic Baseline
Start by confirming whether you’re an obligated producer at all. SB 54 exempts certain small producers below a gross annual revenue threshold, and CalRecycle publishes exemption guidance and procedures on its packaging EPR pages. Check the current guidance rather than assuming you qualify. If you’re not sure, treat yourself as obligated and gather the data.
Next, isolate your 2023 California sales specifically, not global or national totals. If your sales or ERP system doesn’t track units by state, you’ll need a defensible attribution method. A common approach is applying California’s rough share of your U.S. sales (based on population, revenue territory, or distributor shipping data) to your total unit volumes for the year. Document whatever method you use, since it’s the first thing a reviewer will ask about.
For each SKU or product family sold into California in 2023, gather the packaging specification: every component (bottle, cap, label, film, box, void fill) with its material type, weight, and count. Purchase orders, packaging engineering drawings, or supplier-provided bills of materials are usually the fastest source if you didn’t track this at the time. Where specs are missing, some producers physically weigh and count components on a current sample of the same packaging, assuming it hasn’t changed materially since 2023.
For your 2023 source-reduction baseline specifically, isolate just the plastic components (bottles, caps, film, foam, plastic labels) and calculate two numbers per SKU: the number of plastic components, and the weight of only the plastic portion of each component, excluding any paper, metal, or glass parts of a mixed-material component. Multiply each per-unit plastic weight and component count by the number of California units sold in 2023, then sum across all SKUs to get your two baseline figures. Non-plastic materials aren’t part of the source-reduction baseline itself, though you’ll still report them separately, sorted into CalRecycle’s covered material categories, as part of your broader annual supply data.
Special Cases: New Businesses, Missing Data, and Late Filers
If your business had no California sales in 2023, because you didn’t exist yet or hadn’t launched there, your 2023 plastic baseline figures are zero. Confirm with CAA or CalRecycle guidance how a new market entrant’s later-year data should be handled, since the baseline year is fixed at 2023 and doesn’t move to a later year.
If you were obligated in 2023 but simply didn’t track plastic packaging data at the time, you’ll need to reconstruct it after the fact from whatever records exist: 2023 sales ledgers, packaging specs or bills of materials from your suppliers noting material type and component counts, and shipping or distribution records showing what actually moved into California. This is more labor-intensive but is the expected path for many producers who weren’t yet on anyone’s compliance radar in 2023.
Baseline and annual supply reporting run through CAA, which in turn compiles and submits producer-level data to CalRecycle. If you’ve already missed a filing window, don’t skip the baseline entirely. It’s the fixed reference point your plastic-reduction targets get measured against for years to come, so an inaccurate or missing baseline compounds every year after it.
Tips / Common Mistakes
Don’t use company-wide or global packaging figures as a stand-in for California volume. Regulators and CAA expect a documented, state-specific attribution method, not a rough guess. Keep whatever attribution logic and source files you use in a labeled folder; you’ll want to apply the same methodology in later reporting years for consistency.
Watch unit conversions closely. Packaging specs are often in grams while regulatory reporting is often expressed in larger units like pounds or tons, and a missed conversion can throw your entire baseline off by orders of magnitude. Also don’t forget plastic in secondary and tertiary packaging (shipping cases, pallet wrap) if it’s sold with the product rather than used purely for internal logistics. Any plastic covered material in that packaging still counts toward your plastic baseline.
Finally, treat this as a one-time heavy lift, not an annual redo. Once you’ve built and documented your 2023 plastic weight and plastic component-count baseline, your job in future years is comparing current-year data against it, not rebuilding it from scratch.
Explore more: More California packaging compliance guides.
SB 54 2023 baseline packaging weight FAQs
What counts as “packaging” under SB 54?
SB 54’s definition of covered material is broad. It includes primary retail packaging plus certain secondary and tertiary packaging (like shipping cases) sold along with the product, spanning plastic, paper/fiber, glass, and metal material categories. The 2023 source-reduction baseline itself, however, only covers plastic covered material, tracked by the weight of the plastic and by the number of plastic components.
Who actually has to file a 2023 baseline report?
Any “producer” under SB 54, generally the brand owner or company whose name appears on covered packaging sold into California, is obligated unless it qualifies for an exemption such as the small-producer exemption. Check CalRecycle’s current exemption guidance to see whether you qualify.
Is the 2023 baseline only about plastic packaging?
Yes. Under 14 CCR § 18980.9, the 2023 source-reduction baseline is specifically about plastic covered material, measured by the weight of the plastic portion of your packaging and by the number of plastic components. Non-plastic materials like paper, glass, and metal are handled through producers’ broader annual supply reporting instead.
What if I can’t find exact 2023 packaging data?
Reconstruct it as closely as possible from 2023 sales records, supplier packaging specs or bills of materials (noting material type, weight, and component counts), and shipping documentation, and document your methodology and assumptions so you can show your work if asked.
Who do I actually submit the baseline data to?
Producers submit baseline and annual supply data through the Circular Action Alliance (CAA); CAA then compiles and forwards producer-level data to CalRecycle.
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Photo by CHUTTERSNAP on Unsplash.