5 Lessons From EPR Reporting Season 2026 (And Where Brands Lose the Most Money Without Knowing It)

June 1, 2026 was the first consolidated annual EPR reporting deadline under the Circular Action Alliance (CAA), covering six of the seven states with packaging EPR programs. Depending on where you sell, you could have owed up to eight separate reports: three simplified supply reports (Minnesota, Maryland, Washington), three full annual supply reports (Oregon, Colorado, California), and two California-only reports (the Baseline Report and the Annual Source Reduction Report). Colorado and Oregon also offered optional eco-modulation reports for anyone chasing a fee reduction.

If your team felt like it was building the plane while flying it, that's because, in a lot of ways, you were. Some of these programs didn't have final regulations until right before the deadline, and guidance documents and workbooks arrived only weeks before June 1, when teams needed months. 

This was rePurpose's biggest EPR reporting season yet, and I've spent the last few days in a room with our customer success, data ops, product, and engineering teams unpacking everything that went well, everything that didn't, and everything we're building differently next cycle. Here's what we learned from processing thousands of reports, so you can get ahead before the next reporting cycle.

1. "Am I obligated?" is three separate questions, not one

Most brands treat obligation assessment as a single yes-or-no question. It's really five, and they get harder as you go:

1. Do you put anything into the market in this state at all? Fast to answer, and the one question that should be settled before you sign with anyone, not after.
2. Do you meet the state’s revenue thresholds? Most states have a $5M global gross revenue threshold, but some have state-specific revenue eligibility like California. 
3. Which product lines are you obligated for? This is where supply chain hierarchy gets confusing. Licensees and importers need to check both upstream and downstream in their own chain, and plenty of brands don't realize that until a report comes back wrong.
4. Are there specific SKUs you can exempt? The deep, SKU-level work is usually where the savings live, but requires sifting through regulatory and program fine print. 
5. After you’ve exempted eligible product lines or specific SKUs – do you meet the state’s tonnage thresholds for covered materials? Keep in mind that combined revenue thresholds and tonnage thresholds make you eligible for different reporting/fee mechanisms for low vs. high volume producers. 

The brands that came through this cleanly knew which of the questions they were answering at each stage.

2. Your data format is a bigger risk than your data itself

Spreadsheet-based reporting has a specific failure mode: errors surface one at a time, after upload, instead of all at once. A "final" file can still be hiding problems nobody's found yet. The fixes that saved money weren't dramatic – they were basic checks, run consistently, on every report:

• Material misclassifications (an HDPE film logged as LDPE, a labeled "glass closure" that turns out to be a different material entirely) go unnoticed unless someone specifically checks for them.
• Component quantity errors quietly become the single biggest source of "why do I need to regenerate this" requests.
• Missed fee-reduction opportunities sit in the data the whole time. One brand's poly-coated paperboard reclassification was worth roughly $122,000 in savings once someone looked for it. Tillamook's Senior Director of R&D put a number on what a properly reclassified filing was worth to them: "$100,000 - that's how much rePurpose saved us in EPR fees for our Oregon credit. They reviewed our filing and reclassified our materials correctly."

Meredith Wagy at Wild Planet put it plainly after completing her 2026 EPR and Source Reduction filing: "Between data collection, packaging details, sourcing information, and the ever changing reporting requirements, it takes a massive amount of coordination and attention to detail." What made it manageable, she said, was having knowledgeable partners in her corner throughout.

One thing we're taking into next season: getting customers to move away from legacy files earlier, and being clearer upfront about the types of data we need and in what format. Asking for everything at the start – rather than going back and forth – saves weeks.

3. If you're a repeat reporter, you need a paper trail, not just one report

Nobody asks "why is this different from last year" the first time you file. The second time, everybody does. When a component’s material category changes, or a number moves year over year, and nobody can explain why without digging through old emails and chat threads, that gap was always there. Filing twice just makes it visible.

Before your next cycle, ask whoever handles your reporting: if a number changes next year, can you tell me why, in writing, quickly? "We'd have to check a bunch of different places" is the answer worth fixing now, while it's not deadline season.

4. Canada is not "one more state"

If you sell into Canada, it helps to know this isn't a single program bolted onto your U.S. process. It's closer to nine separate programs, each with its own fee structure, exemption thresholds, and material definitions. Canada's Extended Producer Responsibility landscape is also heading toward harmonization soon, which will rewrite the rules again for whoever's paying attention. Brands building Canada-specific knowledge now, ahead of that shift, will have a head start on the ones waiting for it to force the issue.

5. Self-reporting is a lonely and sometimes dangerous journey; having the right partner helps make it easier

We recently had a call with a mid-sized brand that had managed their EPR reporting in-house for the May deadlines. Checking in on how it went, their answers sounded confident – right up until a few details raised enough flags that our Compliance Specialist offered to walk through the CAA portal with them directly. Turns out there were some real gaps underneath that confidence:

1. They misread the OR and CO reporting cycles – assuming "2025 reporting" meant CY 2025 data rather than CY 2024. That meant they'd submitted the wrong year, and CY 2024 had never been filed at all.
2. They believed MN, MD, and WA reporting wasn't live yet, so nothing had been submitted for those states.
3. They mistook California's Early Fees for their final Supply Fees, and had been budgeting off that number ever since.
4. They didn’t incorporate unit sales into California component counts, so those numbers were significantly undercounted and the report was immediately rejected by CAA.
5. They'd leaned heavily on AI for packaging estimations and categorizations and, without deep familiarity with the requirements themselves, had no easy way to check whether the outputs were actually right.

None of this was negligence. It's exactly the kind of gap you'd expect when a brand-new, multi-state system launches and everyone's building the muscle at the same time. But it's a good illustration of why "we handled it in-house and it seemed fine" isn't the same as "it was right." The mistakes were quiet ones – nothing threw an error, nothing looked wrong on its face – which is what made them dangerous.

Before your next reporting cycle

1. Confirm which of the five obligation questions you've actually gotten answered: market presence, revenue exemption, product-line obligation, SKU-level exemption, or tonnage exemption. Most brands have only covered the first.
2. Put a QC checklist in writing, covering material classification, component quantities, and a fee-reduction pass, and confirm it runs on every report, including the easy-looking ones.
3. Ask for your own paper trail. If your numbers move next year, you should get a plain-English answer for why, without anyone launching a research project to find it.
4. If Canada's on your map, start now. Nine programs take longer to learn than one, and harmonization isn't waiting for anyone's Q1.

Multi-state, repeat-reporter EPR is new industry-wide, and everyone is learning at the same time. Put these four items on next quarter's task list so this May doesn't repeat itself next May.

Want to get ahead of source reduction and the next reporting season? Our team is here to help you make EPR simple. Schedule a demo.