How to Build One EPR Reporting Foundation That Scales

How to manage changing program requirements without rebuilding your internal processes for every jurisdiction.

This year, packaging EPR moved from a planning exercise to an active regulatory requirement. Seven states – Maine, Oregon, Colorado, California, Minnesota, Maryland, and Washington – have all enacted extended producer responsibility programs for packaging.

As of mid-2026, producers in Oregon and Colorado are already registering, reporting, and paying fees. And lawmakers in numerous other states have introduced or advanced packaging EPR proposals in 2026.

If you sell packaged products across state lines, it’s no longer a question of whether packaging EPR applies to you. It's how you're going to manage it. Underneath all the program details and deadlines, there’s one core decision to make: will every new state become its own compliance project, or do you build one foundation that can answer them all?

A scalable operating foundation goes beyond a data system and includes consistent ownership, definitions, workflows, documentation, and operational inputs across the business.

The Operating Foundation Behind Scalable EPR Reporting

Faced with a new program, most companies do the reasonable thing, and they set up a project to address it. Someone reads the statute. A spreadsheet gets built. Packaging data is chased down across suppliers, brand teams, and distribution channels. Then the program definitions are interpreted, and the report is prepared and filed. For one state, it’s possible to make that work.

But repeated across seven, the work that’s required and the nuance in program rules compound. Each program needs its own data pulls, its own interpretations, and its own approval cycles to report what you sold and what it was made of.

With every new jurisdiction, the work and inconsistencies grow. And when two states receive two different answers to the same underlying question, both numbers get harder to defend.

The alternative is one governed operating foundation. A single, maintained base of product and packaging information with verified data. Once that’s built, it can be translated into whatever output each state program requires.

Designing EPR Reporting Processes with Flexibility in Mind

One foundation doesn’t mean you can treat every state program the same. They aren't, and the differences are important to recognize and plan for. Covered materials, exemptions, fee structures, deadlines, and report formats all vary, and each still has to be addressed according to the individual program terms.

The efficiency of a single EPR operating foundation doesn't come from flattening those differences. It comes from standardizing the internal work that sits beneath them. All the existing programs include the same underlying question – what did you put on the market, in what materials, in what quantities – asked at different levels of granularity, against different definitions, on different timelines.

If you treat each of those as a separate program, you rebuild the same answer seven ways. But if you work from a unified EPR foundation, you can produce seven cuts of one dataset.

California Shows Where EPR Is Headed

California’s SB 54, for single-use packaging and plastic food serviceware, gives a good sense of what packaging EPR looks like once a program moves from planning into execution:

• The regulations took effect on May 1, 2026.
• Within 30 days, producers had to register and choose a compliance path through the producer responsibility organization (PRO), independent compliance, or claim the small-producer exemption.
• Producers applying to the PRO also had to provide 2023 supply data.
• The first source-reduction target takes effect January 1, 2027, with escalating requirements through 2032.
• The law also authorizes penalties of up to $50,000 per day per violation.

One detail that stands out is the requirement for producers to submit, in 2026, defensible numbers about packaging they sold three years earlier. If the relevant data wasn't part of a validated governance program back then, it likely had to be reconstructed from old spreadsheets, supplier records, and estimates. And reconstructed to a confidence level that producers can stand behind, under a program with real enforcement authority.

Extending Material Tracking to Post-Use

California’s SB 54 doesn’t stop at documenting what producers put on the market. It also extends responsibility to how those materials are collected and recovered after use.

Most companies will meet that responsibility by joining the state’s PRO, but there’s still an underlying operational need – meeting California’s targets will require systems able to collect and recover these materials at scale.

And because producers fund the PRO, they have a financial stake in how well that system performs. Better infrastructure can help control system costs while improving recovery.

What Is an EPR Operating Foundation

A scalable EPR operating foundation is a set of standing decisions about how packaging information is owned, classified, collected, validated, documented, and translated into program-specific outputs:

• Governed product and packaging data, with clear ownership: Accountability for material classification and reporting inputs is established before deadlines force the question.
• One classification taxonomy: Materials are defined once, enterprise-wide, and mapped to each program's categories, rather than reclassified state by state.
• Consistent handling and documentation across sites: When the same material is handled differently across locations, reporting breaks down no matter how good the tracking is.
• A controlled vendor footprint: Every additional waste and recycling provider adds variability in definitions, documentation, and data quality.
• Verification embedded in operations: Data on material movement and outcomes is captured as work happens, not reconstructed at reporting time.

On top of that foundation is a thin translation layer for each jurisdiction – accounting for differences in state definitions, exemptions, deadlines, and formats. That layer is different for every program, but it's also small if the foundation under it is sound.

There’s also a financial reason to get reporting right. Producer fees are tied to the materials a company puts into the market and the cost of managing them. That means weak data doesn’t just create reporting headaches. It can also affect what you pay.

With these programs, data quality stops being a reporting concern and becomes a cost driver.

An Operating Model Decision

Requirements will keep changing. More states are considering packaging EPR laws, and the seven programs already on the books are still taking shape. It’s important to create a foundational plan now. One that can keep up as the rules, reporting expectations, and operational demands evolve.

Some of the hardest gaps to close are operational, not clerical. A scalable EPR foundation has to work beyond the spreadsheet. Complex material streams like product returns, excess inventory, mixed materials, and branded packaging still need controlled handling and documented end-of-life outcomes at a scale most individual sites can't support.

Our ZeroPoint infrastructure was designed to help you manage products and packaging consistently across locations, moving materials from distributed collection points through processing and verified recovery.

The companies best positioned for what comes next will be the ones with operations flexible enough to adapt and controlled enough to verify.

See how consistent material handling, verified data, and centralized reporting can strengthen the operational side of your EPR readiness: Download our EPR Accountability white paper.