Guide: How to prepare your packaging reporting for US EPR programs in 2025

What are EPR policies? 

Extended Producer Responsibility (EPR) policies require producers to take responsibility for the end-of-life management of their packaging materials. Companies selling packaged goods must contribute to recycling, waste reduction, and sustainability initiatives by funding and participating in a Producer Responsibility Organization (PRO).

Several U.S. states have already enacted packaging EPR laws, with more expected to follow suit. These laws require liable producers to register with Circular Action Alliance (the only U.S. PRO), report packaging data, and pay fees based on their material use. On Wednesday, January 29, rePurpose Global will host a webinar detailing EPR regulations and reporting. 

Am I Liable?

Under EPR guidelines, brands take responsibility as the producer of their products, regardless of contracted manufacturing. Definitions and thresholds for who qualifies as a producer vary from state to state. If you sell in multiple states, you may also need to follow multiple processes. You can take rePurpose’s free eligibility survey to determine your obligations and consider the following factors:

• Where you sell packaged products
• The type of packaged products you sell
• Packaging materials (including shipment goods)
• Gross annual revenue
• The amount of covered products you sell

These reporting metrics can shape more than the EPR fees your company will be responsible for. rePurpose Global helps brands navigate the new EPR landscape. Take our EPR liability survey and contact our team to avoid unexpected penalties and set your planning process off in a strategic direction. 

Deadlines are Approaching: Get Ahead of the Fines

The time to prepare for U.S. Packaging Extended Producer Responsibility (EPR) compliance is now. Oregon's Recycling Modernization Act marks the first of many significant packaging EPR deadlines in the U.S., with fees kicking in July 1, 2025.

Given the complexity of gathering accurate packaging data, brands should start compiling information as soon as possible—this process can take weeks, if not months. If you’re not sure where to start, rePurpose Global can help- from helping centralize your reporting data to developing strategies that put that data to work.

Failing to comply can result in substantial fines and reputational damage. Don’t leave your brand out to dry. Take advantage of the opportunity this changing regulatory environment presents and implement an EPR strategy that drives business returns.

Compiling Your Data

To meet EPR reporting requirements, brands must collect specific data about their packaging. Here’s what you need to know:

What Data is Needed?

• Sales volumes by product
• Packaging format (e.g., bottle, box, pouch)
• Packaging components: all material types and weights 
• Attributes (such as PCR content, biodegradability or compostability)

Where Do You Find This Data?

If your team has yet to begin centralizing your packaging data, you may want to schedule a consultation with rePurpose. Your purchase orders, product spec sheets, and bill of materials should be requested from suppliers or manufacturers in spreadsheets or through PLM or ERP systems. Centralizing your packaging data is the first step towards compliance.

If packaging data points are missing, brands will need to use the accepted reporting methodology to fill data gaps. By consulting with the Circular Action Alliance (CAA), rePurpose Global can help compile reliable supply chain data to fill these gaps, verifying reliable data accuracy. To ensure your brand is following best reporting practices, reach out to our team.

Capitalize on Compliance with rePurpose

EPR compliance can be daunting, but it also presents an opportunity. By proactively managing packaging data, brands can:

• Improve product marketing
• Gain shelf space with key retailers
• Enhance consumer engagement
• Strengthen ESG reporting for investors and retailers
• Create authentic messaging points for content, packaging claims, and stakeholders

EPR reporting starts in the U.S. this year, but your brand’s responsibility does not end once you’ve hit submit. With more states moving towards EPR legislation and the growing scope of these policies it is critical to your operations that you create an adaptive plan, tailored to each market you operate in.

Start strategizing today: to comply with deadlines, simplify reporting, and take advantage of your packaging data contact our team. Don’t wait for compliance enforcement—activate your brand’s future today!