California EPR Compliance: Your Step-by-Step Guide

Extended Producer Responsibility (EPR) is an environmental regulatory framework that makes brands responsible for the packaging they put into the world. Under EPR, companies must collect, format, and submit packaging data to each relevant state, then pay fees based on the types and amounts of packaging they use.

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First adopted in Europe and Canada, EPR was designed to shift the financial burden of waste management from the public sector to producers. All fees will go towards funding state-run recycling programs to improve waste collection infrastructure.

Seven states (Oregon, California, Colorado, Minnesota, Maryland, Washington, Maine) have active EPR laws.

You likely need to comply with EPR if you meet these criteria:

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• Above $5 million in global annual revenue or above $1M in annual revenue in California
• Commission single-use packaging, paper products, or food serviceware that feature your brand
• Are a brand owner, importer, licensee, distributor, or retailer with private label products selling into EPR states (such as California, Colorado, or Oregon)

To confirm your eligibility, take our survey and talk to our team.

Non-compliance can result in serious consequences including:
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• Fines up to $50,000 per day in California (fines vary state by state)
• Sales bans and prohibition from selling products in regulated markets.
• Public listing as non-compliant.
• Reputational damage and business disruptions

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In a “DIY” manner, EPR compliance typically takes 2+ months of work per state, from interpreting regulations to compiling data, to manually producing reports with requirements that vary state by state.

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With rePurpose, the process can be reduced to approximately 2 weeks with our prebuilt reporting workflow for each EPR regulation. Our software is equipped with supplier data templates to simplify and support your data collection process. Rather than manual spreadsheets, rePurpose is built to auto-generate audit-ready reports, mapped to each specific state.

Give us 4 weeks to get you compliant, from assessing your obligations to producing your final reports.

You bring the data, and we’ll handle everything else.

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Specifically, for the May 31, 2026 reporting deadline, we’ll need your 2025 packaging supply data, supplier specs and sales data by state, your team’s point person for EPR, and your packaging changes from 2025 for California source reduction tracking.

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We’ll provide you with a North American obligation assessment, automatic deadline tracking across every state, material categorization and fee calculations, state-by-state report generation, California source reduction pathway classification, fee forecasting so you know what's coming before the invoice arrives, dedicated compliance experts reviewing everything and walking you through submission, and continual regulatory monitoring so that you don’t have to read through 1,000 pages as regulations evolve.

EPR reporting requires detailed packaging data, which can be complex to compile and varies by state. Brands must be prepared to report on:
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• Types and amounts of packaging materials used (including component-level details like material type and color)
• Product exemptions and covered materials
• Packaging weights and recyclability information
• Packaging format and component-level detail
• Material categories (there are 140+ categories across different states)
• Sales data by state

To meet these requirements, you'll need data from both internal and supplier sources.

Yes, EPR fees can often be significantly reduced through proper optimization strategies:

• Smart Data Collection: Knowing exactly which data to collect (and which to skip) prevents over-reporting and reduces unnecessary fees. Expert platforms help you avoid "boiling the ocean" hunting for irrelevant information.
• Reporting Option Selection: Many states offer different reporting options for low-volume producers. Expert analysis can identify the most cost-effective choice. For example, rePurpose saved low-volume clients an average of $3,750 in fees by selecting optimal reporting pathways—one brand paid only $360 instead of $4,400.
• Accurate Material Categorization: With 140+ material categories across different states, proper classification is crucial. Misclassification can lead to overpayment, while expert categorization ensures you pay only what's required.
• Exemption Identification: Many products qualify for exemptions that brands miss without expert guidance. Identifying exempt products and covered materials can significantly reduce your fee burden.
• Multi-State Efficiency: Using the right data architecture from the start saves money across all EPR states. Your initial investment pays dividends as you expand compliance to additional states.

You have three main options to navigate EPR compliance, each with distinct advantages and drawbacks:

DIY Approach:

• Pros: Lower upfront cost, full control over process
• Cons: Requires 2+ months of internal work, high risk of errors, no ongoing support, difficult to optimize fees, requires deep regulatory expertise

Consultants:

• Pros: Expert guidance, customized service
• Cons: Expensive ($40,000-$120,000+), project-based with no ongoing platform, limited scalability across multiple states, still requires significant internal coordination

Software Platforms (like rePurpose):

• Pros: Reduces process to ~2 weeks, automated multi-state compliance, ongoing support, fee optimization, scalable across all EPR states, comprehensive data management
• Cons: Not all software platforms are created equal

Most brands find software platforms offer the best balance of cost, efficiency, and ongoing value, especially for companies planning to operate in multiple EPR states.