Who can file a brand's packaging EPR report?
The producer files its own report through CAA's Producer Portal, and a brand can do the work itself or hand the data and filing work to a specialist. The producer is responsible for the report either way, so the real choice is who builds the packaging record and who stays accountable for it. A good provider can show where every weight came from and how the record is kept current.
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Who files
Producers submit reports to CAA, covering the quantities of covered materials they supplied into each state. CAA describes the steps: the producer identifies the person or team that supports the report, selects a methodology for its supply data, and enters and submits the report on the Producer Portal. Registration and signing the Participant Producer Agreement come first.
CAA's reporting guidance is available to producers that have signed that agreement, and much of it sits behind the portal.
Some states let a producer assign its responsibility by contract. Maryland's statute allows it for a person that has joined a registered producer responsibility organization, and a trade summary says Minnesota's law works the same way.
How brands get it done
- In house: one person or team builds the packaging record, collects the specifications and submits the report, using CAA's guidance and Producer Services. This tends to suit a small catalog and someone with the time.
- With software: a tool collects and calculates the data, while the brand still supplies the specifications and checks the results.
- With a specialist firm: a firm builds the packaging record, follows up with suppliers, prepares and files the report and keeps it current.
What separates providers
- Who checks each weight and material, and how that check is shown.
- Whether the documents behind each weight are kept, since CAA can ask for spreadsheets, calculations and images.
- Which states are covered, and how a new state or a rule change is handled.
- What happens when a product or a supplier changes.
- Who owns the data, and whether the brand can take it.
- Who is accountable if CAA requires a correction.
- What the price includes and what it leaves out.
What does not change with any option
The producer registers with CAA, signs the state addendum, reports, and pays its fees or dues to CAA. Fees and dues go to CAA on CAA's invoices, and a provider does not change a deadline. CAA's standard report date is May 31 each year, covering the prior calendar year, unless CAA announces otherwise.
Where FilingTitan fits
FilingTitan is a firm that does the work. We map every product to its packaging components, collect the specifications from suppliers, prepare and file the report in each state and keep it current, with a person checking every line. We cover California, Oregon, Colorado, Minnesota, Washington and Maryland. We are not CAA and not a law firm, and we do not set fees.
How the packaging record is built is covered in kits, sets and bundles in an EPR report and the supplier data an EPR report needs.
Primary sources
- Circular Action Alliance, Producer Reporting: the reporting steps and the Producer Portal
- Circular Action Alliance, Reporting Policy version 1.0: the May 31 report date, methodologies and substantiation
- Circular Action Alliance, Producer Resource Center: guidance for registered producers
- Oregon DEQ, Producers of Covered Products: what a producer must do to file
- Maryland Department of the Environment, packaging EPR report to the General Assembly: the statute's contract assignment provision
- Holland and Knight, are you ready to report your packaging data: CAA's portal guidance and who can reach it
- Printing United Alliance, Minnesota becomes the fifth state with EPR legislation: contract assignment in Minnesota
FAQ
Does CAA file the report for a brand?
No. CAA runs the Producer Portal and offers guidance and support, and the producer submits its report there.
Can a brand hand the whole job to a provider?
In practice, yes. The producer remains responsible for the report. Maryland's statute also lets responsibility be assigned by contract to a person that has joined a registered producer responsibility organization.
Is a brand required to hire a provider?
No. A brand can build the record and submit the report itself.
What does a provider need from a brand?
We start from the product list and the specifications that already exist, then follow up with the suppliers who hold the rest.
What comes first, registration or reporting?
Registration. CAA says producers review its reporting guidance and begin collecting supply data after they complete registration and sign the Participant Producer Agreement.
This guide is general information, not legal advice. Check your exposure to see where you stand, or talk to us.