California's EPR requirements are more detailed than any other state. Here's what makes compliance harder.
California kicks in at $1M in CA state revenue.
California requires 2023 supply data, not 2024.
California requires every plastic component be counted and categorized separately.
Other states use 60+. California uses 95 specific classifications.
Tape on your box? Report it. Plastic window in your mailer? Report it.
Pallets, industrial wrap, business-to-business materials—all get reported.
This is why spreadsheets break down for California. You need software built for this complexity.
Deadline
Supply Data
Key Covered Materials
Reporting Specifics
Fee Information
Early Fees (one time)
EPR Fees
Deadline
Supply Data
Key Covered Materials
Reporting Specifics
Fee Information
Early Fees (one time)
EPR Fees
Deadline
Supply Data
Key Covered Materials
Reporting Specifics
Fee Information
Deadline
Supply Data
Key Covered Materials
Reporting Specifics
Fee Information
Registration opened August 1st with a September 5th deadline. The reporting portal opened September 22nd, and CAISA (California Interim State Addendum) was sent to authorized representatives that same week.
Your 2023 packaging supply data is due. This report establishes California's plastic source reduction baseline and informs the Circular Action Alliance's program plans. While no fees are calculated from this report, the data structure you build now becomes the foundation for all future California reporting.
Once California finalizes its EPR regulations (expected early 2026), you have 30 days to submit an updated report reflecting any regulatory changes.
Your 2025 packaging data is due. This report triggers early fee calculations. Invoices go out in August 2026.
Fees could increase to fund California's $500M plastic pollution mitigation program. Early fee estimates use 7 material classes. Actual fees calculate across all 95 categories.
Oregon and Colorado? You could get by with a spreadsheet and a “Do It Yourself” approach. California breaks that.
Managing 95 categories across hundreds of components means formulas fail. Manual entry creates errors. Version control becomes impossible when multiple people update the same file.
One brand told us: "We handled Oregon and Colorado with spreadsheets. California showed us we needed real software."
Automated component tracking, real-time validation, maintained data integrity across your entire catalog. No formula debugging. No version conflicts.
California's 95 categories aren't intuitive. Is your cardboard box with plastic tape "corrugated cardboard" or "corrugated cardboard with plastic component"? Answer affects your fee tier.
Food serviceware is particularly tricky. Most items have coatings or linings that push them into plastic categories, even when they look paper-based.
We've mapped 140+ material types to California's categories. Our system flags ambiguous cases and provides California-specific guidance.
California won't be your last EPR state. Maine's coming. Minnesota's next, Washington to follow. Smart brands aren't just solving for California—they're building systems that work everywhere.
Your California data architecture becomes your foundation. Adding new states is a configuration change, not starting from scratch.
Earth Animal, a purpose-driven pet brand focused on holistic health, offers a diverse range of foods, treats, and supplements in complex packaging formats. To meet Extended Producer Responsibility (EPR) regulations without straining internal resources, they partnered with rePurpose Global. The result: a streamlined process that took days instead of months—delivering long-term cost savings and valuable packaging data.
Early fees get calculated after your 2026 report (for 2025 data). Invoices arrive August 2026. Current early fee range estimates use 7 categories. Actual fees use all 95.
Our fee optimization engine reviews categorizations and flags opportunities to reduce fees legally. Average savings: $50k-120k.
True Botanicals is a luxurious, consciously crafted skincare brand that offers clean, sustainable, and clinically proven products free of over 5,000 harmful chemicals. With hundreds of SKUs, intricate packaging needs, and limited internal bandwidth to interpret all reporting nuances, True Botanicals turned to rePurpose Global to simplify Extended Producer Responsibility (EPR) compliance—and gained a long-term data advantage in the process.
California requires specific information most brands don't currently track. For each component you need:
Not just "plastic"—you need PET, HDPE, LDPE, PP, PS, or PVC. Not just "paper"—corrugated, paperboard, coated, or laminated?
Which components belong to which SKUs? What quantities?
Pallets, industrial wrap, business-to-business packaging all count.
Suppliers have this data but aren't used to sharing it in this format. You'll need detailed specs for every component.
Report as one entity or multiple? This decision affects threshold calculations and future fees.
You need 2023 data by November 15. If you changed suppliers or packaging in the last two years, tracking that down gets complicated.
Your supplier's "reusable plastic" claim? California has specific rules. Wrong category = wrong fee tier.
California's fee structure is more complex than other states. Here's the timeline.
November 15, 2025
You're establishing your plastic reduction baseline. The state needs starting numbers to measure progress.
May 31, 2026
Triggers early fees. These are placeholder fees while regulations finalize. Invoices: August 2026.
May 31, 2027
Full fees kick in. California's funding a $500M plastic pollution mitigation program. Fees jump significantly from early fee levels.
Right now, California published early fee estimates based on 7 material classes for budgeting purposes.
Actual fees calculate using all 95 categories. Fee per ton varies significantly across categories.
Generic "plastic" early fees versus specific "PET bottle" versus "PET thermoform tray" fees could have different rates.
How you categorize components today affects what you pay in 2026 and beyond. Broad categorization now means you're not optimized for the detailed fee structure coming.
rePurpose categorizes at the 95-category level from day one. When fee structures finalize, you're already optimized.
They can see why selling MadeGood is a benefit for their own packaging and circularity goals."
We guide you through component breakdown and plastic sub-component mapping. Common components auto-populate from our 500+ component library. You're not starting from zero.
We've mapped packaging materials to California's specific categories. Validation flags ambiguous cases before submission.
Track pallets, industrial wrap, and B2B materials alongside consumer packaging. Different reporting requirements handled automatically.
Managing hundreds of SKUs with multiple components each? We maintain your catalog with change tracking. Update a component once, it updates across all affected SKUs.
Reports generated are formatted for California's portal. No manual reformatting. No transcription errors.
Our engine reviews categorizations for optimization opportunities. We flag where conservative choices might cost you unnecessarily.
Your California setup becomes the foundation. Add Oregon, Colorado, Maine, Minnesota—configuration, not new projects.
You're not navigating regulations alone. Our team provides guidance on ambiguous cases, categorization questions, portal submissions.
✓ Automated component tracking
✓ Real-time validation
✓ 95-category material mapping
✓ Pre-submission error detection
✓ Fee optimization recommendations
✓ Multi-state data architecture
✓ Portal-ready exports
✓ Regulatory expert support
Week 1: Data collection, component mapping, categorization
Week 2: Validation, optimization, submission prep
You provide product specs and supplier data. We handle California's complexity.
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"rePurpose Global came in with the tools and deep data expertise to make what could've been stressful, seamless—and we hit our deadline with confidence."
Beyond November:
California's just the beginning. Maine's next. Minnesota after that. More states are coming.Smart brands are building systems now that scale everywhere. That's what rePurpose does.
What working with us looks like:
See your specific situation and timeline
Templates and guidance for gathering specs
Configure for your catalog and components
Components mapped to 95 categories with expert validation
Fee optimization review before submission
Portal-ready reports for California
Ready for 2026 reporting and beyond
See how rePurpose handles California's component reporting, 95 categories, and fee optimization. Walk through your products and timeline with our team.
