If your organization had to complete an EPR submission tomorrow detailing packaging tonnage by material type and jurisdiction, could it do so?
Raised during the IMPACT 2026 Product Stewardship & Supplier Risk Breakroom, this question captures a central challenge facing product stewardship and sustainability teams.
Extended producer responsibility (EPR) shifts more responsibility for managing, reporting, and funding packaging at the end of its useful life toward producers. As state programs expand across the United States, meeting those obligations requires more than interpreting regulations.
Completing an accurate submission depends on connecting packaging composition and weight with product hierarchies, supplier declarations, sales volumes, and jurisdiction-specific classifications. These inputs often sit across teams and systems that are not accustomed to working together. Product stewardship may coordinate the submission, but it cannot resolve disconnected data and unclear ownership alone. EPR is therefore becoming an enterprise data and operating challenge—one that requires consistent definitions, connected workflows, and reliable controls.
Fragmented EPR Requirements are Changing the Compliance Question
The defining feature of the emerging U.S. packaging EPR landscape is not simply that requirements are increasing. It is that programs are taking shape independently. For producers operating across multiple states, the question is shifting from “How do we comply with this law?” to “How do we build a process that can adapt to the next one?”
As Whitney Smith, Senior Consultant at Trinity Consultants, observed during the IMPACT 2026 session, “Every state program is different.” Covered-material definitions, producer responsibility organization structures, fee schedules, reporting timelines, and submission formats can vary by jurisdiction. As a result, producers may need to classify and report the same products and packaging materials differently from one state to another.
Treating each program as a standalone project can create parallel data requests, calculations, interpretations, and approval processes. Randy Burgdorf and Whitney pointed to a more scalable approach: maintain a governed foundation of core product and packaging information, then map it to jurisdiction-specific rules. This allows the compliance process to adapt without embedding regulatory fragmentation into the organization’s workflows—but it depends on product and packaging data that can be reused across programs.
Why EPR compliance starts with packaging data
At its simplest, reportable packaging tonnage connects the weight of each packaging component with the number of applicable units placed into a jurisdiction. The calculation becomes unreliable when information about the product, its packaging, or its destination is missing or inconsistent.
The challenge can begin with defining the unit being reported. During the session, Randy used a beverage example: should the product record represent an individual can, a case, or another sales configuration? That choice affects how the company accounts for the aluminum can, secondary cardboard packaging, and tertiary distribution materials. Product, packaging, and sales systems may represent those relationships differently.
The required inputs can also sit with different owners. Packaging specifications may be maintained by engineering or quality teams, supplier declarations by procurement, sales volumes in an ERP system, and regulatory classifications by product stewardship.
As Whitney explained, “If that data lives in three different systems and nobody owns it, you have a gap that is going to cost you.”
The issue, therefore, is not necessarily that the data does not exist. More often, it exists at the wrong level of detail, relies on inconsistent identifiers, or lacks a clear owner responsible for keeping it accurate and current.
Why packaging choices affect EPR fees
By shifting more end-of-life costs toward producers, EPR turns packaging data into a financial input. Depending on the program, producers may need to register with a producer responsibility organization, report covered materials, and pay fees based on the packaging they place into the market.
Material type, weight, recyclability, and recycled content can influence fee calculations, compliance forecasts, and the organization’s understanding of financial exposure. As Whitney explained during the session, “It isn’t just a compliance story. It’s a design story.” Where fee structures account for packaging characteristics, lighter or more recyclable formats may support sustainability goals while also reducing EPR-related costs.
EPR fees should not determine packaging design on their own. Product protection, safety, performance, availability, and overall cost remain essential considerations. But EPR adds another measurable factor to those decisions, making product stewardship data increasingly relevant to packaging, procurement, finance, and product-development teams.
How AI and digital infrastructure support scalable EPR compliance
Spreadsheets and filing-specific processes may be enough to meet an initial EPR deadline. As products and jurisdictions increase, however, these approaches become harder to control. Additional files, data requests, calculations, and manual handoffs make it difficult to maintain consistent information across the program.
A scalable EPR foundation should include:
- A governed product and packaging inventory: A consistent record connecting products and SKUs with packaging components, materials, weights, and other relevant attributes.
- Repeatable supplier data collection: Standard processes for requesting, validating, updating, and retaining packaging information received from suppliers.
- Jurisdictional mapping: A structured way to connect internal material classifications with the covered-material categories used by different EPR programs.
- Connections to sales and shipment data: The ability to combine packaging profiles with the volume of products placed into each market during the reporting period.
- Clear controls and accountability: Defined data owners, review responsibilities, calculation methodologies, supporting evidence, and change histories.
Alongside these foundational capabilities, AI can support document-heavy work. It can extract relevant information from supplier documents, convert unstructured responses into consistent fields, and flag missing or conflicting records for expert review. This reduces manual effort while keeping regulatory interpretation, data validation, and final approval with product stewardship professionals.
During the session, Randy summarized the practical value of this model: “That way data entry only has to happen once.” The goal is not simply to digitize an individual filing, but to create reliable information that can be maintained centrally and reused across multiple EPR programs.
Explore our Product Stewardship solutions and see how Genny AI supports more connected, efficient compliance workflows.
Build an EPR compliance program that can adapt
EPR compliance does not have a fixed endpoint. New jurisdictions, revised material classifications, changing reporting formats, and evolving product portfolios will continue to reshape what organizations must report.
As Randy noted near the end of the session, “I don’t believe that this is a topic that’s going to be going away anytime soon.” Treating each submission as a separate project will keep teams reacting to change rather than building the capacity to manage it.
A more adaptable approach connects regulatory requirements with governed product and packaging data, clear cross-functional ownership, and reusable workflows. Digital infrastructure and AI can reduce repetitive work, but practitioner expertise remains essential for interpretation, validation, and approval.
Organizations that build for the next requirement—not only the next submission—will be better positioned to manage regulatory complexity, understand financial exposure, and make informed packaging decisions.
