EXTENDED PRODUCER RESPONSIBILITY (EPR) COMPLIANCE FOR U.S. PACKAGING PRODUCERS
Expert advisory for producers navigating the evolving landscape of state-by-state EPR regulations. We deliver cost control, audit defensibility, and operational readiness.
- Extended Producer Responsibility
Strategic Guidance
for U.S. Packaging
Compliance
Expert advisory for producers navigating the evolving land scape of state-by-state EPR regulations. We deliver cost control, audit defensibility, and operational readiness.
- About EPR Global Consulting
Advisory and Compliance Solutions for EPR
- EPR strategy grounded in packaging operations, not theory
- State-by-state compliance readiness across U.S. EPR programs
- Audit-ready documentation, reporting and defensibility
U.S. packaging producers are facing an unprecedented compliance shift as EPR regulations move from policy to enforcement.
EPR Global Consulting was built to close the gap between regulatory requirements and real-world packaging operations,combining hands-on industry experience with defensible compliance execution across evolving state programs.
Our Strategic Goals and Core Objectives
Regulatory Expertise
Interpretation and reporting aligned with Circular Action Alliance requirements, state regulations, and evolving PRO guidance.
Disciplined Cost Control
Standardized, auditable data and calculation logic that supports accurate producer reporting and PRO fee assessments.
Minimize Regulatory Risk
Consistent, validated submissions that reduce data discrepancies, rework, and follow-up inquiries from PROs and regulators.
Long-Term Scalability
A reporting framework
designed to scale
seamlessly
as PRO
programs expand
across states,
materials,
and reporting
cycles.
- Solutions
WHY PRODUCERS FIND
EPR COMPLIANCE Difficult
Fragmented Data
Packaging data lives across internal systems and suppliers, making it difficult to compile consistent, PRO ready submissions.
Missing Expertise
Most organizations lack dedicated EPR expertise, relying on teams and processes built for voluntary or singlestate programs.
State-by-State Complexity
With no federal standard, each state defines producer obligations, materials, and fees differently multiplying reporting effort and risk.
Advisory + Software-Enabled
Compliance
Extended Producer Responsibility (EPR) is an ongoing regulatory obligation that affects cost, governance, and operational risk. We combine advisory expertise with EPR Axis™, our software platform, to help producers manage EPR accurately, defensibly, and at scale.
01
Expert Statutory Interpretation
02
State-Specific Knowledge
03
Accurate Data Alignment
04
Cost Optimization
05
Risk Mitigation
06
Strategic Execution
WHAT PRODUCERS
VALUE MOST
Clear EPR Understanding
Clear, defensible understanding of EPR obligations
Risk Reduction
Reduced risk of over- or under reporting
Audit-Ready Outputs
Comprehensive compliance documentation that withstands
Scalable Framework
A scalable framework that evolves with regulation
WHAT PRODUCERS
VALUE MOST
Packaging formats, data availability, and producer responsibility vary by business model — creating unique compliance risks across U.S. state EPR programs. EPR Global Consulting helps organizations operationalize defensible, state-specific EPR compliance aligned to how their packaging data actually exists.
Unique Regulatory Impacts
Each industry faces distinct EPR exposure driven by packaging composition, producer definitions, and reporting thresholds. Misalignment between regulatory assumptions and operational reality often leads to overpayment, audit risk, or rework.
Typical Data Sources
Effective EPR compliance depends on consolidating fragmented data across:
- Packaging specifications and materials
- SKU-level weight and sales data
- Supplier, importer, or co-packer inputs
- ERP, PLM, and finance systems
Operational Triggers
Organizations engage with EPR when compliance moves from abstract to urgent:
- Entry into newly regulated states
- Packaging redesigns or SKU expansion
- Rising EPR fees or invoice discrepancies
- Internal audit, legal or regulator inquiry
Impacted Industries
Food & Beverage
EPR Compliance for Food & Beverage Packaging Producers
Retail Brands
EPR Compliance for Retail Brands & Private Label Producers
Manufacturers & Importers
EPR Compliance for Manufacturers & Importers | U.S. Packaging EPR
Private Label & Co-Packers
EPR Compliance for Private Label & Co-Packers | Packaging EPR Advisory
Multi-State Producers
Multi-State EPR Compliance for Packaging Producers
Request an
EPR Readiness Assessment
Identify obligations, data gaps, and risk exposure by state and product line.
- How We Deliver
Built to Foster Enduring Regulatory Confidence
EPR compliance demands expert interpretation, accurate data, and resilient systems. Our methodology transforms EPR into a repeatable, auditable, and manageable business process.
Regulatory Interpretation & Applicability
EPR rules vary by state, material, and sales channel. We start by analyzing how these regulations define producer responsibility and reporting scope for your specific business structure.
Data Alignment & Assumption Discipline
Effective compliance requires aligning packaging and product data with regulatory frameworks. We help map internal data to reporting definitions while documenting transparent, defensible assumptions.
Software-Enabled Execution with EPR Axis™
After establishing data foundations, EPR Axis™ applies approved logic to generate structured compliance outputs. The platform ensures cross-state consistency, version control.
Review, Governance & Audit Readiness
Outputs support internal review, oversight, and external audits. Documentation, traceability, and consistency are embedded throughout the process.
Ongoing Adaptation & Scale
EPR is not static. As programs evolve through new rules and states,our methodology adapts supporting updates and expansion without rebuilding your compliance processes.
Engagement Structure
All scope, responsibilities, and deliverables are clearly documented before any engagement begins.
Advisory-Only Support
Expert regulatory interpretation and guidance without software
One-Time Assessments
Time-bound projects for specific compliance needs
Advisory + EPR Axis™
Combined consulting expertise with software enabled compliance
Ongoing Compliance Support
Continuous reporting and regulatory monitoring support services
- EPR Axis™
How EPR Axis Delivers
Defensible EPR Compliance
EPR Axis is designed to operationalize Extended Producer Responsibility compliance not just calculate fees. The platform brings structure, consistency, and audit-ready discipline to EPR data, calculations, and reporting across U.S. jurisdictions. EPR Axis follows a clear, repeatable compliance workflow that aligns regulatory requirements with real-world
packaging operations. EPR Axis applies SOC-2–aligned security controls, including encryption, role-based access, audit logging, and tenant isolation, to protect sensitive regulatory and packaging data. Customers retain full ownership of their data at all times.
Data In → Compliance Logic
Standardize Packaging & Producer Data
EPR Axis begins by normalizing the inputs that drive EPR obligations — eliminating ambiguity before calculations
ever occur.
key inputs included:
- Packaging materials and sub-material classifications
- SKU-level weights and bill-of-material relationships
- Producer responsibility attributes and thresholds
- State-specific applicability and exemptions All data is structured into a single system of record — reducing spreadsheet dependency and ensuring consistency across teams.
Rules-Based Calculation Engine
Apply Jurisdiction-Specific EPR Rules
EPR Axis applies structured, rules-based logic aligned to state EPR frameworks, including:
- Applicable thresholds and de minimis rules
- Material classifications and fee schedules
- Eco-modulation criteria (where applicable)
-
Reporting periods and jurisdictional nuances Calculations are:
•Transparent
•Reproducible
•Version-aware
Every output can be traced back to documented assumptions and inputs
Review, Validate, Defend
Produce Audit-Ready Outputs
EPR Axis generates documentation and reports designed to withstand regulatory scrutiny.
Outputs include:
- Calculation summaries by state and reporting period
- Supporting documentation for assumptions and classifications
- Change logs and version history
- Exportable documentation
- Exportable reports for PROs, regulators, and auditors This enables compliance teams to respond confidently — without post-hoc reconstruction or consultant fire drills.
Financial Visibility & Forecasting
Make EPR Predictable, Not Reactive
By modeling EPR liabilities before invoices are issued, EPR Axis supports:
- Budgeting and accrual planning
- Fee variance analysis
- Scenario modeling for packaging changes
- Reduced invoice surprises and payment risk EPR shifts from an unknown liability to a forecastable compliance cost.
Built for Producers, Not Theory
Designed for Real Packaging Organizations
EPR Axis is purpose-built for:
- Mid-sized and enterprise packaging producers
- Cross-functional teams spanning sustainability, finance, legal, and operations
- Change logs and version history
- Organizations managing EPR obligations across multiple U.S. states The platform reflects how packaging data actually exists — not how regulations assume it does.
Built for Enforcement Reality
Extended Producer Responsibility (EPR) is an ongoing regulatory obligation that affects cost, governance, and operational risk. We combine advisory expertise with EPR Axis™, our software platform, to help producers manage EPR accurately, defensibly, and at scale.
- Regulatory accuracy
- Consistent interpretation
- Long-term defensibility
Every output is designed to withstand scrutiny from regulators, auditors, and internal Legal teams.
- Typical Stakeholders
- General Counsel & Legal Teams
- Compliance & Risk Officers
- CFOs & Finance Leaders
- Supply Chain
- Important Distinction
This is not ESG software
This is not sustainability
reporting
This is compliance infrastructure
- Ready to See How EPR Axis Applies to You?
Identify applicable obligations, data gaps, and potential cost exposure across relevant states.
EPR Axis integrates into existing compliance and financial workflows. It complements your systems it does not compete with them. EPR Axis™ is seamlessly integrated into all our consulting engagements.
- Pricing
Scope-Driven, Case-by-Case
Pricing
Extended Producer Responsibility (EPR) compliance is not a one-size-fits-all service. Scope, complexity, and risk exposure vary significantly based on business structure, packaging footprint, geographic reach, and regulatory timelines.
Scope Factors
- Number of states and EPR programs in scope
- Packaging volume, material mix, and SKU complexity
- Data availability and readiness
Engagement Type
- Assess • Report • Audit • Expand
- Advisory scope and level of ongoing support
- Use of EPR Axis™ software as part of the engagement
- FAQ
Frequently Asked Questions
Find answers to common questions about EPR compliance, our services, and EPR Axis™.
What is Extended Producer Responsibility (EPR)?
Extended Producer Responsibility (EPR) is a regulatory framework that assigns producers financial and
reporting responsibility for the end-of-life management of packaging placed into a regulated state. In the U.S.,
EPR laws are enacted at the state level and vary by jurisdiction in scope, timelines, and requirements.
Who is considered a “producer” under EPR?
In most U.S. EPR laws, the producer is typically the entity that:
• Owns the brand on the packaged product
• Imports packaged goods into the state
• Sells products under a private label
Producer responsibility is often defined through state-specific hierarchies, meaning responsibility may shift
depending on the business model, supply chain, and sales structure.
What types of packaging are typically covered?
Coverage varies by state but generally includes consumer-facing packaging, such as:
• Paper and fiber packaging
• Plastic packaging (rigid and flexible)
• Glass packaging
• Metal packaging
• Multi-material or composite packaging
Some states also include printed paper and certain single-use foodservice items. Exemptions and exclusions
differ by jurisdiction.
Which U.S. states currently have packaging EPR laws?
Several U.S. states have enacted packaging EPR laws, including California, Oregon, Colorado, Maine, and
Minnesota, with additional states advancing legislation or rulemaking. Requirements, timelines, and
enforcement mechanisms vary by state and continue to evolve.
Is EPR a one-time requirement?
No. EPR obligations are ongoing and recurring. Producers must typically register, report packaging data, and
pay applicable fees on a regular basis. Requirements may change over time as regulations are updated through
rulemaking.
Does EPR apply to my company?
EPR applicability depends on multiple factors, including:
• Product and packaging types
• Packaging materials
• Sales channels and geographic footprint
• How each state defines “producer”
Because definitions and thresholds vary by state, applicability must be evaluated on a jurisdiction-byjurisdiction basis.
Who is legally responsible for EPR compliance?
Legal responsibility generally rests with the legally defined producer under each state’s EPR law. This may be a
brand owner, importer, distributor, or retailer depending on the jurisdiction and sales structure. Responsibility
typically cannot be transferred to packaging suppliers or recyclers
How are EPR fees calculated?
EPR fees are generally calculated based on the type, weight, and volume of packaging placed into a state,
adjusted by:
• State-specific fee schedules
• Material classifications
• De minimis thresholds
• Eco-modulation criteria (where applicable)
Fee methodologies vary by jurisdiction, and incorrect assumptions can materially impact total cost.
What happens if a company over-reports or under-reports?
• Over-reporting can result in permanent overpayment of fees and higher ongoing costs.
• Under-reporting may create audit exposure, penalties, interest, and retroactive assessments.
Accurate, defensible reporting is essential to managing both cost and regulatory risk.
When do EPR reporting and fee obligations begin?
Start dates vary by state and may differ for registration, reporting, and fee payment. Many programs phase in
requirements over time. Monitoring effective dates and rulemaking milestones is critical to timely compliance.
Does EPR affect industries differently?
Yes. EPR impacts vary significantly by industry based on packaging formats, data availability, and supply chain
structure. Food & beverage, retail brands, manufacturers, private label operators, and multi-state producers each
face distinct compliance challenges.
What data is required for EPR reporting?
While requirements vary by state, EPR reporting typically relies on:
• Packaging material classifications
• SKU-level packaging weights
• Sales or distribution data by state
• Producer responsibility attributes
• Applicable exemptions or thresholds
Data is often spread across ERP, PLM, packaging specification systems, and supplier inputs.
Why is EPR compliance operationally challenging?
EPR is not just a sustainability issue — it is a data, finance, and audit challenge. Common issues include
fragmented data, inconsistent material definitions, manual spreadsheets, limited visibility into fee calculations,
and difficulty forecasting EPR liabilities.
How does EPR Global Consulting support compliance?
We combine advisory expertise with EPR Axis™, a software-enabled compliance tools to help clients:
• Clarify producer responsibility by state
• Align packaging data with regulatory requirements
• Apply jurisdiction-specific EPR logic
• Produce consistent, audit-ready reporting outputs
Our approach is designed to support accuracy, defensibility, and scalability.
What is EPR Axis™?
EPR Axis™ is our regulatory compliance platform designed to execute client-approved regulatory logic and
generate structured, traceable compliance outputs across applicable U.S. packaging EPR states.
The platform supports data organization, multi-state analysis, and reporting readiness. It does not independently
interpret EPR law or provide legal advice
Does EPR Axis™ replace legal or advisory expertise?
No. EPR Axis™ is designed to support compliance workflows, not replace expert interpretation. Regulatory
analysis, judgment, and approvals remain a critical part of the compliance process.
Can EPR Axis™ adapt as regulations change?
Yes. The platform is designed to support evolving requirements through configurable, state-specific logic,
versioning, and effective-date controls — allowing compliance processes to adapt over time.
When should a company engage EPR Global Consulting?
Organizations typically engage us when:
• New EPR laws create uncertainty
• Reporting or registration deadlines approach
• Audits or regulator inquiries arise
• EPR costs begin increasing unexpectedly
• During mergers, acquisitions, or geographic expansion
Do you work with international companies selling into the U.S.?
Yes. We work with international manufacturers and brand owners selling into U.S. markets, including those
acting as importers of record where EPR obligations may apply.
Is EPR Global Consulting a law firm?
No. EPR Global Consulting is not a law firm and does not provide legal advice. We work alongside client legal
teams and external counsel to support compliant, well-documented EPR programs.
How do we get started?
Engagements typically begin with an initial discussion to understand business structure, packaging footprint,
and geographic exposure, followed by a tailored scope aligned to current compliance needs
Request an EPR Readiness Assessment
Identify applicable obligations, data gaps, and potential risk exposure across regulated states.
- EPR regulations are expanding across the U.S.
Understand Your EPR Exposure Before Fees & Deadlines Hit
Initial Call
Schedule an introductory
discussion
We Review
We assess applicability and
engagement fit
Next Steps
and approach
EPR Global Consulting does not provide legal advice. Submissions are used for
preliminary assessment purposes only.
- Contact Us
Start a Conversation
EPR compliance is a regulated, ongoing business obligation. If your organization is navigating current or upcoming U.S. packaging EPR requirements, we invite you to contact us for an initial discussion. Our conversations are focused, practical, and confidential.
Who We Typically Work With
- Mid-market and enterprise producers
- U.S. packaged-goods brands and manufacturers
- Retailers and private-label brands
- International importers of record
- Multi-state or multi-channel organizations
When Engagement Is Most Valuable
- New EPR laws create producer uncertainty
- Registration, reporting, or fee deadlines near
- Fragmented or unreliable internal data
- Audit or regulator inquiries arise
- Business changes impact compliance
- All inquiries are handled with strict confidentiality. Information shared during initial discussions is treated as private and used solely for general informational purposes. Such exchanges do not constitute legal advice or establish a client relationship.
Qualification Questionnaire
Please provide the following information to help us assess fit and prepare for
a productive discussion.
