You Submitted Your ISRP. You Made It Through 2026 Reporting. Now What?

Frances Mazur-Batistoni

Associate Director

North America

Erin Gregoire

Associate Director

North America

Table of Contents

• Turn an ISRP into action
• Use 2026 reporting as a diagnostic
• Build for requirements that will keep changing
• What's next?

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For producers subject to Extended Producer Responsibility (EPR), 2026 was a milestone year. They navigated new reporting requirements, gathered packaging and sales data from disparate systems and suppliers, developed methodologies to address data gaps. In California, producers also prepared and submitted an Individual Source Reduction Plan (ISRP) under SB 54.

Now that the reports and plans are submitted, the opportunity is to put what was learned to work. Better packaging data can help producers forecast EPR costs and identify where changes will have the greatest impact. Paired with a plan for implementation, it can also be used to compare material savings, operational trade-offs, and potential fee reductions, as well as make a stronger case for internal investment.

Our work supporting producers with 2026 EPR reporting and ISRP development highlighted three immediate priorities:

1. Implement packaging changes that reduce material use and create business value.
2. Improve the data and methods that complicated 2026 reporting.
3. Adapt as CAA programmes, state guidance, and EPR requirements evolve.

01. Implement

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Turn an ISRP into action

ISRP submission under California SB 54 was the starting point, not the finish line.

California’s first source-reduction milestone – a 10% reduction in single-use plastic – is set for 1 January 2027, followed by increasingly ambitious targets through 2032. Now is the time to translate the plan into action.

Start by prioritising source-reduction opportunities against both SB 54 targets and business value. Consider the number of components and the weight of plastic each change could remove, then assess its effects on material and transport costs, EPR fees, product performance and customer experience. Which changes can be implemented quickly, and which require redesign, supplier engagement, testing, or capital investment? Who needs to be involved, and who owns implementation?

A strong business case for this investment should focus on the opportunities that lie within the Actionable Edge – those that are material, proven, and executable, maximising both financial return and impact return. Uncover these opportunities by showing how each suggested change could advance SB 54 targets while affecting material costs, minimising EPR fees, and improving operations and the customer experience. Bring packaging, procurement, operations, finance, commercial, and sustainability teams into the discussion early. The people responsible for a change need to understand the requirement, their role, and the decisions they will be asked to make.

Through Anthesis’ work developing ISRPs and EPR strategies, we have seen how quickly a long list of technically feasible packaging changes can become difficult to prioritise and operationalise.

Scenario modelling can strengthen that prioritisation. Comparing a “do nothing” scenario with interventions that can unlock new value – lightweighting, right-sizing, eliminating components, or changing materials – can help quantify regulatory and commercial implications, informing investment decisions. It also helps teams to weigh trade-offs across the packaging portfolio, including impacts on product performance and customer experience, rather than treating the lowest potential EPR fee as the only measure of a good decision.

While an ISRP established the intended reduction plan, the next phase is determining which opportunities will carry the most impact and financial return, and how, when, and where to implement them.

02. Imrpove

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Use 2026 reporting as a diagnostic

For many, the 2026 EPR reporting process revealed where packaging data and reporting systems needed improvement. These gaps reveal an opportunity to use 2026 as a diagnostic, building key learnings into an improvement plan for 2027.

Across the producers Anthesis supported this year, we saw recurring challenges: incomplete packaging weights, inconsistent material classifications, disconnected SKU and sales datasets, supplier data gaps, and methodologies that relied heavily on manual calculations or assumptions. Some producers we worked with were also managing previous mergers, adding even more complexity to retrieving data and translating it for EPR reporting. Knowing what was sold is not always the same as knowing what packaging materials were supplied into each state.

Documenting 2026 pain points and challenges that made reporting harder than it needed to be can help reveal priorities for 2027, including:

• Strengthening packaging specifications and supplier data requirements
• Standardising material classifications and assumptions
• Improving SKU and state-level sales mapping
• Automating repeatable calculations
• Strengthening QA/QC and documentation

Bringing suppliers into the improvement plan can also help ensure they understand the packaging information that is needed, why it is needed, and when it must be provided.

It is also important to document methodology. Data sources, assumptions, exclusions, estimation approaches, calculation logic, and key decisions should become a living source of truth that can be updated as requirements evolve.

In our work with producers, Anthesis captures the reporting methodology, key decisions, and people involved in a process report. That record helps the next reporting team understand how the 2026 submission was prepared, where gaps remain, and what to improve. It also makes it easier to assess whether a change to source data or an earlier baseline affects later reports.

Perfection isn’t the goal, documentation and improvement are. This year was about getting familiar with the data and identifying the gaps, laying a stronger foundation for next year’s reporting. As a result, our clients now walk away with a documented methodology, a clear improvement strategy, a better understanding of who needs to be involved, and greater confidence heading into next year.

Don’t rebuild the 2026 reporting process in 2027. Build a better one.

03. Adapt

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Build for requirements that will keep changing

2026 submissions captured the requirements and guidance available at a point in time. That landscape will continue to change.

CAA programme plans, state guidance, covered-material classifications, fee structures, reporting methodologies, and implementation timelines are still evolving. California continues to operationalise SB 54, while producers operating nationally must manage requirements across a growing number of state-level EPR programs. CAA develops and administers programme plans; state agencies set and oversee the regulatory requirements. Watching both is important because a programme update and a change in state guidance can have different implications for each business.

That means regulatory monitoring cannot be revisited only when the next reporting deadline approaches.

Instead, establish clear ownership for monitoring CAA and state developments, assess the implications of each change, and translate those changes into updated data, methodology, financial forecasts, and packaging strategy.

This has been a critical consideration in Anthesis’ EPR work: methodologies built for requirements today also need to be flexible enough to accommodate requirements tomorrow. Rather than creating separate processes for every new requirement, look for opportunities to build a common data and governance foundation that can adapt across jurisdictions and reporting cycles. This can look like adding columns to data to easily filter against various sales channels, licensed products, plastic only weights, recycled content, and other factors. State-specific incentives and rules may still lead to different outcomes for the same packaging change, so test important decisions across all relevant markets.

Processes should be designed to respond and adapt to regulatory change, not predict it.

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What’s next?

Coming out of 2026 reporting and looking ahead toward ISRP implementation and 2027 reporting, businesses should:

1. Use scenario modelling to prioritise and implement packaging changes that both reduce material use and maximise business value.
2. Document pain points and challenges from 2026 to develop improved processes for 2027.
3. Establish clear ownership of regulatory monitoring and build adaptability into data management and reporting processes.

Anthesis helps organisations look beyond EPR reporting to understand the broader business implications of compliance requirements. Combining packaging expertise, regulatory insight, data management, and business transformation capabilities, we help producers assess fee exposure, strengthen reporting processes, and identify practical packaging priorities.