How do kits, sets and bundles work in a packaging EPR report?

Why a set is not one item

State packaging reports ask how much packaging you supplied, in pounds, by material category. CAA, the organization that runs the reports in several states, describes its standard report as supplied pounds in each state's reporting categories, with a methodology and the brands covered.

A set stacks several layers of packaging. There are the tubes, jars or bottles that hold each product, then the retail box, sleeve, tray or insert that holds the set, then the mailer or carton it travels in, plus any filler. Each layer is made of something different and weighs something different. One line for the whole set hides all of that.

Who is responsible for which layer

Oregon's environmental agency, DEQ, explains this for online sales. The company that packs and ships the order is the producer of the shipping packaging. The producer of the original packaging is the same as it would be in a store, which is typically the brand owner. A brand that assembles its own set and ships it to a customer in Oregon therefore carries both layers.

If a set includes other companies' products, who reports which layer depends on the facts. DEQ says its own summary does not cover every scenario, so for those sets we confirm the answer with CAA's producer support team before anything is reported.

What to record for every piece

Each component in each set gets one row with:

• the component, for example a retail box or a mailer
• the material it is made of, including coatings, labels or mixed layers, which can change the category
• its weight as shipped
• how many of it go into each set
• which set or product it belongs to
• the supplier and where the specification came from

Where set reports go wrong

• The whole set is entered as one item with one weight.
• Layers added at packing time, such as the shipper and the filler, are left out.
• The same item is treated as product in one set and as packaging in another.
• Weights are guessed. CAA validates reports, can ask for substantiation such as spreadsheets and calculations, and can require a correction when a material is misclassified or placed in the wrong category.
• A set changes, with a new box or insert, and the record does not.

Weights you can defend

CAA publishes accepted reporting methodologies for registered producers. A producer may use another method, but must explain in the report why it is more accurate. A weight from a supplier specification or from a scale is the easiest to defend. CAA's reporting policy asks for every decimal to be kept during the calculation and for the final figures to be rounded to two decimal places.

California counts components too

For plastic, California looks at more than weight. CalRecycle's source reduction guidance counts the plastic components in each unit and works through examples such as a bottle with a paper label. A set with several plastic pieces is worth counting that way from the start.

When the work is due

CAA's standard report date is May 31 each year, covering the prior calendar year, unless CAA announces otherwise. The component list is easiest to build now, while the packaging is on hand and suppliers are easy to reach.