Our Director of Product, Alyssa Dizon, makes the case in Chain Store Age that retailers have been treating EPR as a vendor problem.
May 31, 2026 made that hard to sustain. California, Colorado, Oregon, Minnesota, Maryland, and Washington all landed on the same Annual Supply Report deadline for the first time, and it exposed how much of the reporting burden actually sits with the retailer.
Let’s start with a private label: under most state programs, the retailer, not the contract manufacturer, is the "producer" of store-brand packaging, and that obligation doesn't move upstream just because someone else made the product.
The piece also digs into where the operational gaps show up. Reconciling vendor packaging data at retail scale means chasing hundreds of vendors submitting data in hundreds of formats, and the best-prepared retailers fixed this months before the deadline by standardizing what vendors submit and folding it into onboarding. Most vendor contracts were never written to require component-level material data on a compliance schedule, so retailers are often left holding the fee or compliance gap with little contractual recourse when vendor numbers are late or wrong. Dizon closes on an often-missed category, e-commerce and fulfillment packaging (mailers, void fill, tape, shipping boxes): it belongs to whoever's brand is on it, which is frequently the retailer, and that exposure follows shelf presence state by state regardless of where the company is headquartered.
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