Key Takeaways
Just Born Quality Confections transformed its approach to extended producer responsibility by treating EPR as a packaging data problem rather than a regulatory one, creating a simple Excel-based model that calculates packaging weight by component combined with sales volume to generate required reporting information across multiple states.
- Core insight: All EPR regulations require largely the same underlying data—packaging weight shipped into each state's market
- Solution: Just Born built a simple Excel model multiplying packaging weight per case by state sales volume, eliminating the need for specialized EPR software
- Data foundation: An intern manually weighed packaging components from the warehouse to create a clean, trusted data source for accurate calculations
- Volume allocation: The company uses each state's share of U.S. population to determine where products are sold, creating a consistent and defensible method
- Expanded value: The initial reporting tool evolved into a forecasting and planning tool that identifies plastic footprint, evaluates material swaps, and supports package launches
“EPR isn’t a policy issue—it’s a packaging data problem.”
That was the realization that changed how Charlotte Ashcraft approached extended producer responsibility at Just Born Quality Confections. Ashcraft had spent months trying to understand every state law, every reporting rule, and every regulatory nuance. Each time she thought she had caught up, another state moved the goalposts.
Ashcraft, senior manager of packaging and graphics development at Just Born, shared the company’s experience at Packaging World’s Packaging Recycling Summit, held in June in Rosemont, Ill. Just Born is the family-owned candy company behind Peeps, Mike and Ike, Hot Tamales, and Goldenberg Peanut Chews.
When Ashcraft first heard about EPR at an industry conference several years ago, she remembers thinking that it sounded like a very big and potentially expensive issue. She also suspected that no one else at Just Born Quality Confections knew it was coming, and she hoped someone else would take responsibility for it.
“Two of those things were true,” she said. EPR did prove to be a significant issue, and Ashcraft was right that it had not yet gained much attention within the company. The part she got wrong was that someone else would handle it. Instead, she brought the issue back to Just Born, raised the flag internally, and ultimately took it on herself.
EPR became her responsibility, from collecting the data and filing reports through invoice payment. Just Born had no established internal structure for handling the work. “We don’t have a dedicated EPR function, we don’t have an enterprise reporting system, and we don’t have a team for data,” Ashcraft said. “We have me.”
Finding the common denominator
Just Born has national distribution, hundreds of SKUs, and numerous packaging formats. Ashcraft’s first instinct was to treat EPR as a policy problem and master each state’s requirements before deciding what to build.
That approach quickly became unmanageable. She stepped back and looked at what the programs were actually asking producers to provide. “All the regulations are different, but the underlying data is largely the same,” she said. “We needed to tell them how much packaging we’re shipping into their state’s market.”
The starting point was packaging weight by component. Once the company had that, Ashcraft could combine it with sales volume to generate much of the information required for reporting.
The problem was that Just Born did not have a clean, trusted source for those weights. Ashcraft requested an intern, who spent the summer pulling packaging components from the warehouse, logging them, and weighing them. “It sounds really monotonous, and it was, but it was arguably one of the most important parts of this entire process,” she said. “If your inputs are wrong, your model doesn’t matter, your formulas don’t matter, your outputs are wrong, and so are your fees.”
Building a model in Excel
The system Ashcraft created does not rely on specialized EPR software, SAP, or Power BI. It lives in Excel.
“At its core, EPR is really just asking you your packaging weight per case multiplied by your state volume,” she said.
Just Born’s Excel-based model calculates packaging weight per case, applies a prorated estimate of annual sales volume for each state, and generates material-specific values for EPR reporting to the Circular Action Alliance.Charlotte Ashcraft, Just Born Quality Confections
The model calculates the amount of primary packaging in each case by multiplying the consumer unit weight by the case count. Secondary and pallet materials can also be allocated to each case when a state requires them.
Determining where products are sold is less straightforward. Just Born often loses the chain of custody once products reach a customer’s distribution center. A shipment sent to a warehouse in Oregon, for example, may ultimately be sold elsewhere.
The company chose to allocate volume based on each state’s share of the U.S. population. Ashcraft does not claim that the method is exact. Its value is that it’s consistent, repeatable, transparent, and based on publicly available information. “Perfect data is rare, but defensible data is achievable when you’re working on this,” she said.
From reporting to package planning
Ashcraft originally expected the spreadsheet to help Just Born submit reports and estimate fees. Once the data was organized, people began asking different questions. The model can show the company’s total plastic footprint, identify which SKUs account for the most exposure, and estimate what would happen if a film were lightweighted by 10%. It can also help Ashcraft evaluate material swaps, package launches, future line trials, and EPR budgets.
“I thought I built a reporting tool,” she said. “But it became so much more valuable over time.”
Ashcraft’s advice for CPGs preparing for EPR is to begin before every requirement is understood, document assumptions, focus on reliable inputs, and build a flexible process rather than wait for a perfect system.Charlotte Ashcraft, Just Born Quality Confections
Ashcraft also uses generative AI to help interpret newly released legislation. She uploads a bill and asks targeted questions about producer definitions, deadlines, fees, and differences from existing programs. The answers provide a starting point, not a compliance decision or substitute for legal counsel.
Looking back, Ashcraft would begin organizing the packaging data sooner, document assumptions from the start, and spend less time waiting to understand every rule. “The spreadsheet started as a reporting tool, changed into a forecasting tool, and now I’m using it as a planning tool,” she said. “Once you understand your packaging data, you’re no longer reacting to EPR, you’re planning for it.” PW
