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Latest updates on plastics and batteries

How producers must show they are reducing plastic

Under California’s Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54), producers of covered material must demonstrate measurable progress toward statutory plastic source reduction targets.

Two distinct, but related, deliverables are required of producers:

1. Individual Source Reduction (ISR) Plan: a forward‑looking planning submission that describes how a producer intends to achieve future source reduction targets
2. Source Reduction Report: an annual, backward‑looking report documenting actual plastic supplied and verified source reduction outcomes

Although closely linked, these documents serve different purposes, follow different timelines, and rely on different types of data (strategy vs. actuals).

Read more about the requirements and timelines here.

Battery EPR accelerates in four states

Battery EPR is entering a new expansion phase in the US, with three new state laws adopted in April 2026 (Oregon, Wisconsin, Kentucky) and a major upgrade of Maine’s legacy regime. While most states are converging on a mandatory, producer-funded stewardship model, Kentucky stands out with a softer, voluntary approach.

This development builds on the emergence of a more harmonised “new-generation” battery EPR framework – previously led by states such as California, Washington, and Vermont – which is now being adopted more rapidly across additional jurisdictions.

The new laws broadly align in scope, covering portable and medium-format batteries as well as batteries in products where they are easily removable, but differ significantly in system design.

Oregon, Wisconsin, and Maine follow a more structured model with clearly defined producer obligations, while Kentucky adopts a softer approach.

Rather than imposing direct obligations on producers, the law establishes a state-led framework that enables the formation of “voluntary” battery stewardship organisations and regulates those organisations once established. As a result, mandatory requirements fall primarily on approved stewardship organisations, while producer participation is not explicitly required.

Implementation timelines vary across the four states, with regimes expected to commence in 2027 (Kentucky, Wisconsin, Maine) through to 2029 in Oregon.

Overall, for producers, battery EPR obligations are broadening in scope and spreading across jurisdictions. However, some differences in regime design – notably targets, convenience standards, and mandatory participation – will continue to shape compliance strategies.