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CASE STUDY

EPR Readiness

What Extended Producer Responsibility EPR Readiness Requires — and How Mark Anthony Brewing Helped Build the Infrastructure to Meet It

A co-innovation story with Mark Anthony Brewing and Trinity Consultants — and what it reveals about building scalable packaging data for state-by-state EPR reporting

INDUSTRY
Food & Beverage

PARTNERS
Trinity Consultants

SOLUTION
Product Steward

U.S. states with active packaging EPR programs

~1.5M

Suppliers managed in Product Steward

7.6M+

Items & parts under governance

Executive Outcome Summary

Extended Producer Responsibility is turning packaging into a compliance dataset — one that must be understood by material type, weight, SKU, sales destination, reporting year, and state-specific program requirements. As EPR programs expand across U.S. states, producers that cannot answer basic questions about their packaging composition, supplier materials, and jurisdiction-specific volumes face a growing operational and financial exposure. This case study examines how Mark Anthony Brewing collaborated with Trinity Consultants and the Benchmark Gensuite team to advance extended producer responsibility EPR readiness through Product Steward — building a reusable packaging data foundation designed to support evolving Producer Responsibility Organization requirements while strengthening broader product stewardship and sustainability initiatives.

Organization Context

Preparing Packaging Data for an Evolving Regulatory Landscape

Extended Producer Responsibility represents a fundamental shift in how producers manage packaging compliance. For decades, municipalities and taxpayers largely funded the collection, sorting, and processing of packaging waste. Today, packaging EPR legislation increasingly transfers financial and reporting responsibility to the organizations placing packaged products into commerce — and producers must now maintain comprehensive visibility into packaging composition, material weights, supplier-provided information, product hierarchies, sales destinations, and jurisdiction-specific reporting requirements.

As of mid-2026, seven U.S. states — California, Colorado, Maine, Maryland, Minnesota, Oregon, and Washington — have enacted packaging EPR programs. Although these programs share similar objectives, each introduces unique reporting schedules, covered material definitions, fee structures, and Producer Responsibility Organization (PRO) requirements. Circular Action Alliance serves as the approved PRO in California, Colorado, Maryland, Minnesota, Oregon, and Washington, requiring producers to prepare increasingly detailed packaging supply reports and material declarations.

Recognizing the operational implications of these evolving regulations, the Benchmark Gensuite team — led by Randy Bergdorf, Director of Stewardship and Supply Chain Solutions — engaged directly with Mark Anthony Brewing and Trinity Consultants to shape practical packaging management capabilities within Product Steward. Whitney Smith, Senior Consultant at Trinity Consultants, brought regulatory depth and circular economy context to the collaboration, helping ensure the resulting workflows reflect the compliance realities producers face across multiple jurisdictions.

Regulatory Context

EPR transforms packaging from a product attribute into a governed compliance dataset — one that must be traceable by material, weight, SKU, and jurisdiction.

The Challenge

When Packaging Becomes Governed Compliance Data

Extended Producer Responsibility transforms how producers must think about packaging information. Rather than simply knowing what packaging is used, producers must understand packaging materials by type, weight, product, sales destination, reporting year, and jurisdiction — and that information must remain sufficiently traceable to support state-specific reporting requirements while adapting to changing regulatory definitions and obligations.

“If you put a product into commerce, you bear the responsibility for what happens when the consumer is done with it.” — Whitney Smith, Senior Consultant, Trinity Consultants

For manufacturers, food and beverage companies, consumer products organizations, and industrial producers, the resulting data requirements extend well beyond annual reporting. Packaging specifications, supplier declarations, product data, and sales information frequently reside in separate systems managed by different business functions. Product stewardship, sustainability, legal, procurement, operations, and engineering teams may each own portions of the information needed to complete a single EPR submission.

“EPR compliance requires you to know your packaging materials by type, by weight, by SKU, across every state where you sell.” — Whitney Smith, Trinity Consultants

The complexity compounds as individual state programs establish different covered material definitions, reporting schedules, fee structures, and PRO requirements. Manual collection processes that may have supported earlier compliance programs become increasingly difficult to sustain as regulations expand. Smith drew a direct comparison to chemical inventory reporting following the Emergency Planning and Community Right-to-Know Act (EPCRA): organizations that successfully matured those programs did not continue producing reports manually each year — they invested in the underlying data infrastructure that allowed compliance reporting to become repeatable, scalable, and auditable. The same principle applies to extended producer responsibility EPR readiness.

The Partnership

Co-Innovating a Scalable Approach to Extended Producer Responsibility EPR Readiness

Benchmark Gensuite’s work to support Extended Producer Responsibility did not begin with U.S. state packaging programs. Earlier development efforts focused on European Union packaging and packaging waste requirements, providing an initial foundation for managing packaging-related compliance data. As U.S. packaging EPR legislation accelerated, the Benchmark Gensuite team expanded that work through active collaboration with Mark Anthony Brewing and regulatory guidance from Trinity Consultants.

Rather than developing a one-time reporting solution, the collaboration centered on a broader operational question: how can producers build a framework that supports today’s reporting obligations while remaining flexible enough to adapt as new states, reporting requirements, and PRO expectations emerge?

“How do we create an infrastructure to allow you as subscribers to manage this effectively, not just this year, but years to come?” — Randy Bergdorf, Benchmark Gensuite

That objective shaped the Product Steward roadmap. The focus was not simply generating reports for current state programs, but creating a repeatable data model capable of supporting long-term extended producer responsibility EPR readiness. Mark Anthony Brewing provided an ideal operational use case for this collaborative development effort. Beverage manufacturers manage complex packaging configurations that frequently include primary, secondary, and tertiary packaging across multiple product and distribution formats. A single product may require decisions about whether reporting should occur at the individual container, case, multipack, or another SKU level — with each packaging component carrying different material classifications, weights, and regulatory attributes. These real-world requirements helped shape Product Steward functionality around the practical challenges producers face when preparing packaging data for EPR reporting.

The Solution

Building a Connected Packaging Data Workflow for EPR Reporting

The Benchmark Gensuite team is extending Product Steward to help organizations establish a reusable packaging data foundation capable of supporting state-specific EPR reporting requirements. Rather than creating isolated reporting workflows for individual jurisdictions, the solution centers on connecting product information, packaging profiles, supplier data, material classifications, and sales information within a common operational framework.

Product and SKU management
Organizations maintain inventories of products and SKUs distributed across multiple states and markets. For beverage manufacturers, this includes determining the appropriate reporting unit — individual containers, cases, multipacks, or other sales configurations — a decision that shapes how packaging data flows through every downstream reporting obligation.
Standardized packaging profiles
Each product is associated with a packaging profile that documents primary, secondary, and tertiary packaging components, capturing material classifications, covered material categories, packaging weights, recycled content, and packaging hierarchy relationships. This creates a standardized representation of packaging data that can be reused across multiple reporting programs rather than rebuilt for each reporting cycle.
Material classification and state mapping
While many EPR programs organize reporting around common material classes such as plastic, metal, glass, wood, and paper, individual states frequently define covered materials differently. Benchmark Gensuite is collaborating with Trinity Consultants on a mapping approach that enables organizations to maintain packaging information once while aligning it to multiple state-specific reporting requirements — reducing duplicate data management as the number of participating states grows.
State-level sales data integration
Packaging information alone is insufficient for EPR reporting. The workflow is designed to associate packaging profiles with sales or shipment data by reporting year, state, product, and SKU. Connecting packaging composition with product distribution enables organizations to calculate jurisdiction-specific packaging volumes using a consistent, governed data foundation.
Producer Responsibility Organization reporting outputs
The intended outcome is a reporting process that helps producers understand the quantity and composition of packaging introduced into each participating jurisdiction while supporting submissions required by individual PROs. Rather than recreating packaging data for every reporting cycle, organizations leverage the same governed information across multiple reporting programs as requirements continue to evolve.
Structured supplier engagement through the supplier portal
Much of the information required for packaging reporting originates with suppliers. Product Steward’s supplier portal supports direct engagement at both the supplier and item level — critical when the question is not simply whether a supplier is compliant, but what the specific material composition, weight, or packaging attribute is for an individual component or SKU. For organizations already using the portal for REACH, RoHS, and conflict minerals, expanding into packaging-related data collection leverages established supplier relationships and familiar workflows.
AI-enabled supplier document extraction
Suppliers do not always complete portal questionnaires directly. Instead, they may submit PDF documents, Word declarations, or email responses indicating whether a product contains a regulated substance or meets a packaging specification. Benchmark Gensuite has released phase-one AI-powered Optical Character Recognition (OCR) functionality in the supplier portal to extract information from supplier-provided documents and pre-fill portions of a material compliance survey — reducing manual review effort at scale while preserving human approval authority over final submissions.

Without EPR, sustainable packaging is going to be a cost center for you. With EPR, unsustainable packaging is going to end up being a liability.

Whitney Smith — Senior Consultant, Trinity Consultants

The Results

A Platform Foundation Built for Long-Term EPR Readiness

Product Steward was originally introduced to help organizations manage product compliance obligations such as REACH and RoHS. Over time, it has expanded to support supplier engagement, item and part inventories, packaging information, raw materials, chemicals, supplier-product relationships, bill of material (BOM) structures, and reporting for compliance programs including REACH, RoHS, PFAS, conflict minerals, and California Proposition 65. That breadth is what makes it the right operational starting point for EPR: the supplier relationships, product hierarchies, and material data structures EPR requires already exist within the platform.

As Bergdorf observed, EPR, Scope 3, product sustainability, and product carbon footprint workflows increasingly depend on the same underlying product data architecture. Organizations that establish governed packaging and product information today are better positioned to respond as sustainability and regulatory requirements continue to converge — without rebuilding data foundations for each new obligation.

“We are going to continue to see a convergence between product and operational sustainability.” — Randy Bergdorf, Benchmark Gensuite

The following figures reflect the current scale of the Product Steward subscriber community — illustrating the operational foundation on which EPR functionality is being built.

Product Steward subscribers
Benchmark Gensuite platform-wide

~15,000

Users across the subscriber community
Benchmark Gensuite platform-wide

~1.5M

Suppliers managed in Product Steward
Benchmark Gensuite platform-wide

7.6M+

Items and parts under governance
Benchmark Gensuite platform-wide

Before & After

How Extended Producer Responsibility EPR Readiness Changes Packaging Data Management

The table below illustrates the operational shift this collaboration is designed to enable — from fragmented, manual packaging data management toward a governed, reusable data foundation capable of supporting ongoing state-specific EPR reporting requirements.

BEFORE	AFTER
Packaging information dispersed across spreadsheets, ERP systems, supplier documentation, and institutional knowledge	Standardized packaging profiles connected to products, suppliers, and bill of material structures in Product Steward
Manual data collection rebuilt separately for each reporting cycle	Reusable packaging data supporting ongoing state-specific reporting without annual reconstruction
Limited visibility into packaging composition by product and jurisdiction	SKU-level traceability across packaging materials, products, suppliers, and sales destinations
Packaging reporting owned by multiple disconnected business functions	Shared data foundation supporting Product Stewardship, Sustainability, Procurement, and Regulatory teams
Supplier packaging information collected inconsistently, often via email or manual follow-up	Structured supplier engagement through the Product Steward portal with AI-assisted document extraction
Individual state reporting managed as a separate annual compliance exercise	Common packaging data aligned to multiple state requirements through back-end material mapping

Regulatory Insight

“If you had to report your packaging tonnage by material weight across six different states tomorrow, do you have that data? Does it exist? And do you know where it lives?”

Whitney Smith, Senior Consultant, Trinity Consultants

Lessons Learned

Building EPR Readiness Begins Long Before Reporting Deadlines

The collaboration between Mark Anthony Brewing, Trinity Consultants, and the Benchmark Gensuite team illustrates several broader lessons for organizations preparing for Extended Producer Responsibility requirements.

EPR readiness is fundamentally a data governance initiative
Successful reporting depends on trusted packaging, supplier, product, and sales data rather than annual reporting activities alone. Organizations that treat EPR as a year-round data management responsibility are better positioned than those that approach it as a periodic compliance exercise.
Packaging data should be managed as enterprise information
Organizations benefit from treating packaging profiles, material classifications, and bill of material relationships as governed operational assets that support multiple business processes — not siloed data owned by a single function.
Supplier engagement is essential
Much of the information required for packaging reporting originates with suppliers. Consistent supplier engagement workflows improve data completeness while reducing manual follow-up — particularly as supplier populations grow and reporting obligations expand across additional states.
Reusable data models scale more effectively than jurisdiction-specific processes
As additional states introduce packaging EPR programs, organizations with standardized packaging data will be better positioned to adapt without rebuilding reporting workflows from scratch. The mapping approach Benchmark Gensuite is developing with Trinity Consultants is designed specifically to reduce this duplication.
Product stewardship is increasingly connected to broader sustainability initiatives
Packaging stewardship, Scope 3 reporting, product sustainability, and product compliance increasingly rely on the same underlying product and supplier information. Organizations that invest in a shared product data foundation today create compounding value across multiple program areas.

Broader Industry Relevance

Why Extended Producer Responsibility EPR Readiness Extends Beyond Regulatory Compliance

Extended Producer Responsibility represents more than another environmental reporting requirement. It reflects a broader shift toward product-level transparency, material traceability, and enterprise data governance. Organizations preparing for packaging EPR requirements are increasingly discovering that the same operational capabilities supporting regulatory reporting also strengthen supplier sustainability programs, product compliance initiatives, Scope 3 data collection, and product carbon footprint reporting.

The EPR landscape is also shifting the business case for packaging design in a way that product stewardship, sustainability, and procurement teams cannot address in isolation. When fees are structured around packaging weight, recyclability, material type, or recycled content, packaging decisions carry direct financial consequences. That creates a practical need for shared data infrastructure capable of answering cross-functional questions:

Which SKUs contain which packaging materials, and what are the material weights by state?
Which suppliers hold missing or incomplete packaging data?
Which packaging formats could generate higher fees under current or emerging state definitions?
Can the same product data support EPR reporting, Scope 3 calculations, and product sustainability initiatives?
How will reporting obligations change as additional states come online?

The collaboration between Mark Anthony Brewing, Trinity Consultants, and the Benchmark Gensuite team demonstrates one approach to building the packaging data infrastructure that underpins long-term extended producer responsibility EPR readiness — one designed to support today’s state programs and adapt as requirements continue to evolve.

ORGANIZATION

Benchmark Gensuite customer since 2022

Industry

Food & Beverage

Partners

Trinity Consultants

Scope

U.S. Packaging EPR

Solutions Used

Product Steward

Supplier Portal

AI OCR Extraction

TOPICS

EPR Readiness

Packaging Compliance

Product Stewardship

Scope 3

Supplier Engagement

PRO Reporting

Bill of Materials

Circular Economy

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