Success Story: Two 25% targets, one credible plan
Client Overview
A large fulfillment program set out to cut flexible plastic and de-risk rising EPR exposure. Adept led two moves: replacing plastic mailers with recyclable paper mailers, and shifting lighter, smaller products out of corrugated boxes into right-sized paper mailers. The economics below are shown per unit — scale them to your own volume.
The Challenge
SB 54 sets two independent source reduction obligations, each 25% below the 2023 baseline by 2032: one on plastic weight and one on plastic component count. A plan that hits the weight target through lightweighting alone fails the component-count target, and at least 10 of the 25 points must come from reuse, refill, or elimination. The client needed a plan that satisfied all three tests, not just the easy one.
Our Approach
We ran a bottoms-up teardown of all 40 packaging formats, using confirmed component weights against California volumes, and built a format-by-format opportunity matrix. Every lever was scored on six effort factors and mapped to weight, component count, and the reuse-refill-elimination floor. Recyclability status was assessed per format against the California CMC list, and recycled content was treated correctly as a separate, capped alternative-compliance mechanism.
The Impact
2023 baseline quantified | 1.43M lbs · 98M components | |
25% cut required by 2032 | ~356,500 lbs · ~24.5M components | |
Reduction plan identified | ~213,000 lbs (central estimate) | |
Top-10 bottle lightweighting | ~78,000 lbs, about 22% of the weight cut | |
Elimination | close to 12M components removed | |
Recycled content leadership | committed near 4.8x the confirmed cap | |
THE RISK WE CAUGHT
The binding constraint was not weight, it was the elimination floor. At least 142,607 pounds had to come from reuse, refill, or elimination, and only about 21,000 floor-eligible pounds existed in the identified levers, a gap near 121,000 pounds that thinner packaging and recycled content cannot close. We flagged this as the single largest compliance risk in the plan and scoped the structural programs to close it: concentrate-plus-refill on dressings, bulk dispensing in foodservice, and SKU consolidation. That is the difference between a plan that looks compliant and one that survives CAA review.
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