Our September webinars drew questions from teams at every stage of EPR compliance, from companies still figuring out whether they're in scope to producers deep into state reporting. The same questions came up again and again, so we've rounded up the most common ones below, covering scope, exemptions, fees, PCR, reuse, and more. If one of these has been on your mind, you're in good company.
Want answers specific to your business? Talk to our team about your EPR questions or see how rePurpose simplifies reporting across every state you sell into.
Getting started
Q: Our current systems don't capture all the data we need, and major changes are unlikely in the next two to three years. Where should an early-stage organization start?
You're not alone. EPR moved fast, and most companies weren't set up for it. Aim for good enough, not perfect. There's a core set of data you'll want to collect through supplier engagement. Take a phased approach: identify what's essential, then build it into your team's existing workflows. Spreadsheets get hard to maintain as states keep changing what they ask for, which is why rePurpose keeps all your EPR data in one place. The right data can also reduce your fees.
Q: Which state's laws apply: where the product is made, or where it's sold?
Where the packaging is sold or distributed. State EPR laws are written around material sold, offered for sale, imported, or distributed into the state. California goes a step further and treats the sale as happening where the material is delivered to the purchaser. So report by destination state using your shipment or sales data. For e-commerce, that means the ship-to address.
Q: If we qualify for an exemption, for example, because we only sell B2B, do we still need to register and report?
Usually, yes, and the details vary by state. In most states, B2B is an exemption for certain materials, not for the producer as a whole. California, for example, includes B2B packaging, so you'd still register and report there. Even when you are exempt, most states expect you to tell the PRO. Don't ignore it. Contact our team to review your situation and learn more about B2B exemptions in our guide.
Q: How do you define a SKU? Is it a product or a product component?
A SKU is typically the entire product. Sales volume is applied at the SKU level. For EPR reporting, you break each SKU down into its individual packaging components, such as a bottle, cap, label, and carton, and classify each one.
Q: Do we report on materials other than plastic?
Yes. EPR isn't just a plastics law. You report on every material in your primary, secondary, and tertiary packaging, including paper, glass, and metal. Some states also cover paper products. Each state defines its own scope of covered materials and its own exemptions, so check what's in scope wherever you sell.
Q: What are the small producer exemption requirements? Do they use global sales or state-specific sales?
It depends on the state:
- Colorado: Global gross total revenue less than an inflation-adjusted limit (currently ~$5.6 million as of July 2025) OR used less than 1 ton of covered material in the state.
- Oregon: Global gross revenue of less than $5,000,000 OR sold less than 1 metric ton of covered products in the state.
- California: Gross sales in the state of less than $1,000,000. Unlike the other states, California does not offer an alternative "under 1 ton" exemption pathway for small producers.
- Maryland: Global gross revenue of less than $2,000,000 OR introduced less than 1 ton of covered material into the state.
- Minnesota: Global gross revenue of less than $2,000,000 OR introduced less than 1 ton of covered material into the state.
- Washington: Global gross revenue of less than $5,000,000 OR introduced less than 1 ton of covered materials into the state.
- Maine: Total gross revenue of less than $2,000,000 OR sold less than 1 ton of packaging material in the state. (Note: Maine also has a "low-volume producer" category for those supplying between 1 and 15 tons, which allows them to pay a flat fee rather than detailed material-specific fees).
Revenue thresholds tend to be global, while tonnage tests are measured per state. That means you need to know your volume in each state before you can tell whether you fall under its threshold.
Fees, budgeting, and invoices
Q: How should we budget for fees before final fee schedules are released?
Start with CAA's draft fees, which you can download from the CAA Portal. Draft schedules give a price range for each material category. The final schedules, which CAA will publish in October, replace those ranges with a single value per category. Let your finance team know to expect two updates: draft first, then final.
CAA published illustrative fees only for the first program year (California, Oregon, and Colorado) and hasn't repeated them since. For programs past their first year, we add a ±10% buffer. The rePurpose app updates your fee projections automatically as schedules are released.
Q: Where will state fees and invoices come from? What should our finance team look for?
- Fee schedules: Registered producers can see these in the CAA producer portal, with a PDF for each state.
- Invoices: CAA sends invoices via email to your authorized representative.
- Payment: Invoices are paid in the CAA Payment Portal, which is separate from the standard reporting portal.
Q: Will California bonus/malus fees be paid in 2028?
Yes. Bonus/malus payments begin in 2028.
Q: Will we be able to see projected fees for Maryland and Minnesota?
Neither state has published rates yet, and neither will until its program plan is published: Maryland and Minnesota both expected in 2028. Until then, there's no cost base to project from. We'll add projections as soon as fee ranges become available.
Q: Are there penalties for overreporting?
The biggest cost of overreporting is overpaying your EPR fees, which is why accurate data matters. If you find an error in a submitted report, contact CAA to file an amendment.
PCR and APR certification
Q: Will CalRecycle provide guidance we can share with suppliers to help them get APR certification for next year?
Not that we've heard. Work directly with your suppliers and APR to move certification forward; most suppliers are already familiar with the process. APR provides the documentation, and CalRecycle may ask for it if you claim APR-certified PCR toward bonuses. rePurpose's document storage lets you keep it ready in case CAA or CalRecycle asks for it.
Q: Will California accept PCR certifications other than APR's?
Not currently. APR is the only certification California plans to accept.
Q: What if PCR doesn't work for our packaging?
PCR is only one reduction pathway. If it isn't feasible for your packaging, explore the alternatives. You can model every reduction pathway in the rePurpose Packaging Simulator to compare options before committing.
Reuse
Q: What are some examples of B2B prefill reuse formats for California?
Common examples include:
- Reusable kegs for beverage distribution to bars and restaurants
- Reusable IBC totes or drums for bulk liquid ingredients shipped between manufacturers and co-packers
- Reusable crates or bins that move product from a manufacturer to a retailer or distribution center
What these have in common: the packaging is designed and marketed as reusable, moves between two businesses rather than to consumers, and is returned for refill instead of being thrown away. These formats only count if they meet California's regulatory reuse requirements, meaning the packaging must be tracked through return, cleaning, and reuse for the same product.
Still have questions?
EPR requirements keep evolving, and no two companies' situations are the same. If you have a question we didn't cover here, or you're ready to spend less time on spreadsheets and more time on strategy, our team can help. rePurpose brings your packaging data, fee projections, and state reporting into one place, so you can stay compliant across every state you sell into and find ways to lower your fees along the way. Contact our team to get your questions answered or see the platform in action.
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