Extended Producer Responsibility (EPR) is no longer a future consideration in the United States. Seven states have already enacted packaging regulations related to EPR, each with different timelines, definitions, and reporting requirements, with more are expected to follow.
EPR shifts financial and operational responsibility for packaging waste from governments and taxpayers to the producers of consumer goods and packaging. That includes funding collection, recycling and recovery programs. But the real challenge is not the policy shift. It is the inconsistencies across states that can lead to confusion and reporting complexity.
Today, manufacturers face a “seven states, seven rulebooks” reality. Each state defines packaging materials, categories and reporting inputs differently. The same product can require multiple interpretations of the same underlying data. What looks like a regulatory challenge is, in practice, a data infrastructure problem.
Most organizations have packaging data, but it isn’t as detailed, structured or consistent at the level required to keep up. Without that foundation, compliance becomes manual, duplicative and difficult to support the existing patchwork of regulations, let alone scale as new states follow. The path forward is building a data foundation that can flex across all state mandates. This playbook outlines three practical moves manufacturers can take now to manage EPR complexity, build a consistent data foundation, and stay ahead of evolving state requirements.
Play #1: Identify component-level data or expect gaps
EPR raises expectations for how materials including packaging are managed. States are now requiring under law for producers to report detailed packaging data – including material types (such as paper, plastic, or glass), weights, and in many cases, individual packaging components. This level of detail was not previously required to be captured or reported on.
What to do
Begin by building a complete view of packaging across the product portfolio, ensuring packaging data is clearly linked to the products it supports. Pull together specifications from internal systems and supplier inputs, then break down individual components to capture the details that matter like material type, weight, recyclability and where each component sits – from pallets to shrink wrap to boxes and labels.
Standardized identifiers such as Global Trade Item Numbers (GTINs) make this possible at scale. They allow companies to connect packaging components directly to specific products and maintain those relationships across systems, suppliers and markets.
Why this works
Without component-level visibility, companies rely on averages or assumptions. That leads to financial inconsistencies, reporting discrepancies, audit risk and rework.
Detailed data replaces those estimates with precise, product-specific calculations. It also makes it easier to understand how materials flow across the product portfolio, so companies can identify opportunities to reduce packaging and improve recyclability.
Play #2: Structure data once, use it everywhere
Once companies have a clear view of their packaging, the next hurdle is how that data needs to be reported. Every state requires similar information, but they use it differently.
What to do
Put a repeatable process in place for translating product and packaging data into state-specific requirements. Define how data is captured, classified, and maintained across internal systems and supplier inputs, then map that standardized dataset to each state’s requirements. Use consistent identifiers and standardized formats so the same data can move across partners and Producer Responsibility Organizations (PROs) without being reworked each time.
Why this works
While states ask for similar information, they use that data to evaluate different things. For example, Oregon’s Recycling Modernization Act focuses on collecting and reporting the total volume of packaging materials such as plastic, paper and metal placed in the market. In contrast, California’s SB 54 uses similar inputs but ties it to recyclability, recycling rates and overall packaging reduction.
Without a standardized foundation, teams often have to rework or manually adapt reports for each state. With one structured dataset, the same data can be translated across frameworks, reducing duplication and improving consistency.
Play #3: Design for flexibility, not static regulation
If there’s one constant with EPR right now, it’s change. New requirements are likely to come, while existing programs are still being refined.
What to do
Build systems and processes that can absorb change without forcing teams to start over. That means managing product and packaging data together, and establishing governance around how that data is maintained, overseen and evolves over time.
Stay closely aligned with key stakeholders like suppliers and PROs to incorporate updated packaging details, requirements and new guidance as it emerges.
Companies can further strengthen their data foundation by connecting packaging data to product movement across the supply chain. Technologies like 2D barcodes and event-level EPCIS data – a data sharing standard for capturing and sharing product status, location, movement and chain of custody across trading partners – enable richer product and packaging information to be captured and shared as products move, improving accuracy and traceability.
Why this works
Static systems break quickly in a dynamic regulatory environment. Flexible, standards-based data systems allow companies to adapt without rebuilding from scratch.
Materials change, suppliers update specifications, and new reporting requirements continue to emerge. Companies with flexible data systems are better positioned for reporting accuracy, audit readiness and reducing regulatory risk when supply lines – and scrutiny – shifts.
The bottom line: EPR as a catalyst for better data
EPR will continue to expand. More states will introduce requirements, and expectations for transparency will increase.
Companies that approach EPR as a series of one-off reporting exercises will fall behind. The ones that invest in structured, standardized packaging data will be able to adapt as rules change.
The next step is practical. Take this playbook and run with it – audit your current packaging data against EPR requirements at the component level. Identify where data is incomplete, inconsistent, or disconnected from products. Align that data to standardized frameworks so it can scale across systems, partners, and regulatory frameworks.
The number of EPR rulebooks will keep growing. The ability to navigate them depends on whether your data is built to handle all of them.
