Short answer: Use this checklist to assess how ready your brand is for packaging EPR. It covers obligation screening, ownership, product catalog, packaging specifications, state sales, evidence, registration, reporting, fee planning and recurring maintenance. Every item is here on the page; the downloadable version is optional.
The checklist
1. Obligation screening
- List every brand you sell and who owns, licenses or imports it.
- List the states where products are sold or shipped, including through distributors and e-commerce.
- Identify which of the seven EPR states are in your footprint.
- Review each state's producer hierarchy for each brand and channel.
- Evaluate exemptions and thresholds in each state and document the basis.
- Note questions that need confirmation from the program or counsel.
2. Organizational ownership
- Name one owner for EPR compliance.
- Identify contacts in finance, operations, procurement and sustainability.
- Agree who approves registrations and submissions.
- Set a budget line for producer fees and compliance support.
3. Product catalog
- Export a current SKU list with descriptions, brands and pack sizes.
- Flag discontinued SKUs still sold during the data year.
- Group SKUs that share packaging configurations.
- Identify kits, variety packs and private label items.
4. Packaging specifications
- Break each packaging configuration into components.
- Record material, material detail and format for each component.
- Record weight per component in a consistent unit.
- Capture primary, secondary, transport and e-commerce packaging.
- Request missing specs from suppliers and co-packers.
- Record recycled content where available.
5. State sales
- Export units sold or shipped by SKU and ship-to state for the data year.
- Choose and document an allocation method for distributor and retailer sales.
- Reconcile state totals to overall sales.
6. Evidence
- Keep the source document for every weight and material value.
- Record the evidence type: spec, supplier declaration, measured sample or estimate.
- Log assumptions and how they were derived.
- Store export files and search criteria used.
7. Registration
- Confirm registration status with each applicable PRO or program.
- Calendar registration windows, including Maine's 90-day window once its SO is selected.
- Keep registration confirmations on file.
8. Reporting
- Calendar each program's reporting deadline and data year.
- Map components to each program's material categories.
- Prepare outputs in each program's required format.
- Review and approve before submission.
9. Fee planning
- Estimate fee exposure using available program rates.
- Model scenarios for packaging changes and new states.
- Separate producer fees from compliance-service costs in your budget.
10. Recurring maintenance
- Version packaging records when components or suppliers change.
- Add new SKUs to the packaging record at launch.
- Review program updates at least monthly during active rulemaking.
- Refresh sales data each reporting cycle.
How to use it
Work through the sections in order. Obligation screening tells you which states matter; ownership makes sure someone drives the work; the catalog, specifications and sales sections build your data; evidence makes it defensible; and the last four sections turn it into a repeatable process. If most items in a section are unchecked, that is where to start.
For detail on the data sections, see packaging data for EPR reporting. For state specifics, see packaging EPR laws by state.