What packaging data does an EPR report need from suppliers?
An EPR report needs four things from a supplier for every packaging component: what it is made of, what it weighs, how it is built, and a document that proves it. The weight and the material set the fee, and CAA can ask for the spreadsheets, calculations and images behind any figure. A number that came from a supplier specification or a scale holds up when it is checked, and a guessed one does not.
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What we collect for each component
For every component of every product, we collect:
- the component and the product or set it belongs to
- the material it is made of, including coatings, labels, liners and mixed layers
- its weight as shipped, with the unit
- anything else that decides its material category, such as whether it is rigid or flexible
- how many of it go into each product or set
- for plastic, the number of plastic components in each unit
- the supplier, the date of the specification and where the document is kept
Why each field matters
State packaging reports ask how much packaging a producer supplied, in pounds, by material category. The material decides the category, and the weight decides the amount. Coatings, labels and mixed layers can change which category a piece belongs in, so they are recorded with the material.
CAA can require a correction when a material is misclassified or placed in the wrong category. For plastic, California looks at more than weight: CalRecycle's guidance counts the plastic components in each unit, with worked examples such as a bottle with a paper label. A component list that already has the count answers that question once.
What proof looks like
CAA validates reports and can ask for substantiation, which it describes as items such as spreadsheets, calculations and images. A supplier specification sheet, a scale weight with a photo, and a note of how a calculation was done are the kinds of records that answer that request.
CAA publishes accepted reporting methodologies for registered producers. A producer may use another method, but has to explain in the report why it is more accurate. Documented estimates are allowed when they reasonably reflect what was supplied. A weight from a supplier or a scale is the easiest to defend.
Where supplier data goes wrong
- A specification lists a nominal weight that differs from the weight of the unit as shipped.
- A part changes after a redesign and the specification does not.
- One sheet covers a whole family of items, and the exact component is not identified.
- Labels, coatings and inks are left out of the material.
- Packing layers added late, such as the shipper and the filler, are missing.
- Weights arrive in mixed units and are converted inconsistently.
How we keep it current
The record is checked again when a product or a supplier changes, and again before each reporting cycle. CAA's standard report date is May 31 each year, covering the prior calendar year, unless CAA announces otherwise. CAA's reporting policy asks for every decimal to be kept during a calculation and for the final figures to be rounded to two decimal places.
How a set or kit is broken into rows is covered in kits, sets and bundles in an EPR report.
Primary sources
- Circular Action Alliance, Reporting Policy version 1.0: report structure, methodologies, substantiation, corrections and rounding
- Circular Action Alliance, Producer Resource Center: guidance for registered producers
- CalRecycle, Source Reduction Reporting Guidance: how plastic components are counted
- Oregon DEQ, Producers of Covered Products: what a producer must do to file, including applying a reporting methodology
FAQ
How precise do the weights need to be?
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.
Is a spreadsheet enough as proof?
CAA lists spreadsheets, calculations and images as examples of what it can ask for. Which records answer a request depends on what CAA asks about, so the source documents are kept with the spreadsheet.
Does the same data work for every state?
Most states that CAA serves ask for packaging weight by material category, so one component record feeds all of them. Some states add items of their own, such as California's count of plastic components.
How often does supplier data need to be refreshed?
Reports are annual, but a redesign or a supplier change can alter a component at any time. The record is updated when that happens and checked again before each report.
This guide is general information, not legal advice. We collect this data from every supplier, check it by hand, prepare and file the report each cycle and keep it current. Check your exposure to see where you stand, or talk to us.