Packaging EPR glossary

Packaging EPR terms, explained clearly.

The terms that matter for packaging EPR compliance, defined clearly and linked to deeper guides.

Author: CertaRelayRequirements may change. Verify current obligations with the applicable agency, PRO or qualified counsel.

Short answer: Plain-English definitions of the packaging EPR terms you will meet in state laws, PRO guidance and reporting templates. Definitions are general; each state defines its terms in its own law and regulations.

Extended Producer Responsibility (EPR)
A policy approach that makes producers financially, and sometimes operationally, responsible for the end-of-life management of their products or packaging. Packaging EPR applies this to packaging and paper. See packaging EPR compliance.
Producer
The company a state law makes responsible for covered packaging. Each state defines it through a hierarchy that usually starts with the brand owner. See laws by state.
Producer Responsibility Organization (PRO)
An organization approved to run an EPR program on behalf of producers: registering them, collecting reports and fees, and funding recycling. Circular Action Alliance is the PRO in several states.
Covered material
The packaging and paper a program applies to, as defined in each state's law and regulations. Scope differs by state.
Packaging component
An individual physical part of a package, such as a bottle, cap, label, carton or film. EPR reporting is built from component-level data. See packaging data.
Primary packaging
Packaging in direct contact with the product or forming the unit a consumer buys.
Secondary packaging
Packaging that groups primary units for sale or display, such as a multipack carton.
Tertiary packaging
Transport packaging used to move goods through distribution, such as corrugated cases and stretch wrap.
Packaging bill of materials (BOM)
A structured list of every packaging component for a SKU, with material, format, weight and quantity per unit. Different from an item master.
Eco-modulation
Adjusting EPR fees up or down based on packaging attributes such as recyclability, recycled content or reuse. See EPR fees.
Recyclability
Whether packaging can be collected, sorted and recycled in practice under a program's criteria. States define and determine recyclability differently.
Source reduction
Reducing the amount of packaging material used, for example by lightweighting or eliminating components. California's SB 54 sets source-reduction targets for single-use plastic. See the California guide.
De minimis exemption
An exemption for very small quantities, either for producers below a threshold or for small packaging components, depending on the state.
Reporting year
The year in which a producer submits a report to a program.
Data year
The period whose sales and packaging data a report covers, often the prior calendar year.
Program year
The period a program's fees and operations apply to. Reporting year, data year and program year can all differ.
Next step

Find out what your packaging data is missing.

The EPR Readiness & Data Assessment, from $1,000, reviews your states, reporting status and data gaps, and ends with a fixed proposal. The full fee is credited if you proceed within 60 days.