EPR Reporting Readiness: Managing Obligations Efficiently

The expansion of state-level Extended Producer Responsibility, or EPR, is changing the way companies think about packaging. What was once viewed as a downstream waste issue is now becoming a front-end business issue tied to data, governance, reporting, and cost.

What EPR Means for Corporations

Extended Producer Responsibility (EPR) shifts packaging waste responsibility to producers—brand owners, importers, distributors, retailers—for tracking, reporting, and possible fees across 6 active U.S. states in 2026: Oregon, Colorado, California, Minnesota, Washington, and Maryland.

Companies may be covered in one state but not another, and the definition of a “covered producer” can vary depending on the jurisdiction. That makes early scoping essential.

Why This Matters

Key 2026 deadlines:

• Oregon, California, Washington, Maryland & Colorado: Reports due May 31, 2026
• Oregon, California, Minnesota & Colorado: Portals opened March 31
• Washington & Maryland: Portals opening April 23

If considered a covered producer, companies must track packaging data (weights, materials, volumes) across products sold in a state and report in the required formats. The real challenge: building internal systems to locate data and ensure accuracy.

What Companies Can do Now

The most effective response is to treat EPR as a readiness process, not a one-time filing exercise. In the near term, companies should focus on establishing a reliable baseline that supports timely, accurate reporting and reduces the risk of last-minute surprises.

1. Assess: Identify if you're considered a “covered producer" and confirm obligations across jurisdictions
2. Measure: Build a packaging materials inventory, calculate state-specific packaging volumes and compare to the regulation thresholds
3. Report: Develop a defensible calculation methodology and where required, prepare state-specific filings

This work also tends to reveal broader organizational needs. EPR will require coordination across sustainability, legal, procurement, packaging, operations, finance, and compliance teams, and companies that build a repeatable process now will be better positioned to capture more business value in the future.

Long-Term Opportunity

Although EPR is a compliance obligation, it also creates an opportunity to reduce waste, strengthen packaging strategy and lower costs.

Companies that invest in better data and governance can use EPR to drive smarter packaging decisions – lighter materials, reusable formats, optimized designs – that cut waste streams, lower disposal fees, and shrink environmental impact., more efficient reporting processes, and stronger internal accountability.

Over time, the companies that move from reactive compliance to proactive management will be able to confidently manage obligations across jurisdictions while achieving tangible waste reduction and cost savings as regulations evolve.

Our Perspective

At Third Economy, we help companies navigate reporting like EPR with a practical, structured approach.

That includes regulatory scoping, packaging data assessment, measurement and analysis, and disclosure development, with the objective of achieving packaging EPR reporting readiness across applicable jurisdictions.

Our perspective is simple: companies that start early, build a clear inventory, and close data gaps methodically will meet near-term obligations, reduce waste and costs, and position themselves for long-term financial gains. 

The regulatory details are here — but there's still time to prepare. If you'd like help assessing your exposure and drafting a reporting strategy, reach out to our team.

Disclaimer: The information provided does not, and is not intended to, constitute legal advice; instead, all information, content, and materials available are for general informational purposes only.