Extended Producer Responsibility is moving from concept to compliance, and quickly. During a recent webinar hosted by the Pet Sustainability Coalition titled, “EPR for Pet Brands: Navigating the 2026 Multi-State Deadline,” Lowell Huffman, director of channel partnerships at rePurpose Global, walked attendees through what to expect and how to prepare.
The session blended policy updates with practical guidance, with a clear focus on what brands actually need to do next. It also mirrored what many companies are dealing with as EPR shifts from something they have been tracking to something they now have to execute. Requirements vary by state, deadlines are approaching quickly, and the amount of data involved is more extensive than many teams anticipated.
Huffman opened by acknowledging the weight of the topic and commending attendees for taking the time to engage with a complex and often daunting subject. “EPR is a hot topic, but it’s one that a lot of people would have every reason to avoid and not show up to grapple with,” he said.
He framed the discussion around the scale of change required, not just in packaging design, but in how companies collect, manage, and report information. “What we are trying to do with these EPR schemes across these states is a substantial amount of change, and change is very hard for human beings,” Huffman said. That change, he noted, is happening quickly and often without the benefit of long lead times.
The regulatory environment itself adds to the challenge. Huffman described it as evolving “faster than any trend on TikTok,” with updates occurring frequently and sometimes altering reporting expectations midstream. For brands trying to build repeatable processes, that constant motion can make planning difficult.
At the same time, he emphasized that the work is necessary and already underway. Several states have completed initial reporting cycles, invoices are being issued, and enforcement mechanisms are taking shape. For many companies, the question is no longer whether EPR applies, but how quickly they can get organized.
A shifting regulatory landscape
EPR is often described in simple terms, but its implications for brands are anything but simple. At its core, the policy framework shifts financial responsibility for packaging waste from municipalities to the companies that place packaging on the market. Instead of cities and taxpayers covering the cost of collection, sorting, and processing, brands are assessed fees based on the materials they use.
Those fees are meant to shape behavior. Materials that are difficult to recycle or that lack established end markets carry higher costs, while materials that are widely recyclable or part of reuse systems carry lower fees. Over time, that fee structure is intended to move companies toward packaging formats that are easier to manage within existing recovery systems. The policy has two central aims. One is to fund recycling infrastructure that has struggled to keep pace with the volume and complexity of modern packaging. The other is to encourage better packaging design through eco-modulation, where material choices have direct financial consequences.
As Huffman explained during the webinar, the operating structure behind EPR adds another layer of complexity. States pass the laws and assign regulatory authority to agencies such as CalRecycle in California or the Department of Environmental Quality in Oregon. Those agencies then work with producer responsibility organizations, or PROs, to manage implementation. The Circular Action Alliance currently serves as the primary PRO for most of the states with EPR packaging laws, coordinating reporting, fee collection, and compliance support across multiple jurisdictions.
For brands, the result is a system that is partially centralized but still highly variable from state to state. Definitions of “producer,” reporting thresholds, and covered material categories are not uniform. A company may be obligated in one state and exempt in another based on revenue thresholds, packaging volumes, or how its role in the supply chain is defined.
“A producer can mean different things depending on how a state defines a liable entity,” Huffman said. “There are a million or almost infinite scenarios where you might be a parent or a subsidiary,” he adds, underscoring how company structure can complicate the determination.
That patchwork is becoming more important as the map expands. Seven states already have active EPR laws, including Oregon, Colorado, California, Maryland, Maine, Minnesota, and Washington. Additional states are advancing legislation, and Huffman noted that adoption is expected to continue at a pace of several states per year.
The broader takeaway is that EPR can no longer be treated as a one-off compliance exercise. Systems built for one state will need to scale across others, often with different requirements, timelines, and definitions. For brands just getting started, that variability may be one of the clearest signals that EPR is no longer a packaging issue alone. It is quickly becoming an operational one.
Deadlines are converging
The regulatory complexity is compounded by timing. Several states are now aligned around similar reporting windows, with May 31, 2026, emerging as a key deadline for annual supply reports and early program reporting.
A snapshot of 2026 EPR reporting deadlines shows multiple states aligning around a May 31 due date, alongside additional California source reduction reporting and Maine start-up requirements.Pet Sustainability Coalition/rePurpose Global
Huffman described the run-up to that deadline as a coordinated effort that requires multiple teams to move together. Data must be collected, validated, categorized, and submitted, often within a compressed timeframe. “There’s a tremendous amount of work that has to get done,” he said, noting that companies are working across multiple data years and reporting formats at once.
Early reporting cycles are already revealing where things can go off track. Some companies have been asked to revisit submissions when data does not align, a signal that oversight is becoming more structured. Missing a step or rushing the sequence can lead to costly corrections later, along with potential penalties that can reach tens of thousands of dollars per day.
California raises the stakes
California continues to stand apart because of both scale and ambition. The state’s SB 54 legislation sets targets for recyclability, recycling rates, and source reduction that extend well beyond initial reporting requirements.
Huffman noted that many brands that felt comfortable navigating earlier programs are encountering new challenges in California. “SB 54 does kind of create a whole different challenge that I think are throwing people for a loop,” he said.
California’s SB 54 combines recyclability, recycling rate targets, and source reduction goals to drive systemic change in packaging by 2032.Pet Sustainability Coalition/rePurpose Global
A key element is the requirement to establish a 2023 baseline and then show measurable progress over time in reducing plastic packaging. That baseline becomes the reference point for reduction targets tied to both the total weight of plastic and the number of plastic components placed on the market. Under California’s framework, producers are expected to demonstrate a 10% reduction by 2027, 20% by 2030, and 25% by 2032, achieved through strategies such as elimination, lightweighting, and reuse or refill models. The level of detail required, including small components that might previously have been overlooked, adds to the complexity.
The California program illustrates how EPR is evolving from a reporting exercise into something more operational. Companies are not only documenting what they use, but also planning how to change it over time.
A step-by-step path to compliance
To help brands navigate that complexity, Huffman outlined a six-step process that emphasizes sequence and coordination. It begins with determining obligations, followed by compiling packaging and sales data, selecting reporting methods, submitting reports, and paying fees.
To explain why order matters, Huffman compared the process to a dance. “EPR is kind of a beautiful ballet, if you will,” he said. “A certain number of things have to happen in a certain sequence, and if you do them out of order, it can kind of mess up the beauty of the outcome.”
EPR compliance follows a structured six-step process, from determining obligations and compiling data to reporting, fee payment, and ongoing annual updates.Pet Sustainability Coalition/rePurpose Global
That idea carries through each step. Determining obligations sets the foundation, and errors there can affect everything downstream. Compiling data requires coordination across systems and partners. Choosing a reporting method affects how fees are calculated and how results are interpreted.
Huffman also compared the process to navigating a tax code, where different choices can lead to different outcomes. The goal is not just compliance, but accurate compliance, avoiding both underreporting and unnecessary costs.
Data is the real work
At its core, EPR reporting comes down to a calculation of how much packaging is placed into each state and what that packaging consists of. Huffman described it as “a relatively simple equation,” but one that quickly becomes more involved in practice because the data is scattered across systems, suppliers, and internal teams.
Packaging specifications are often held by suppliers, while sales and distribution data live within internal systems. Pulling those pieces together requires coordination across functions and, in many cases, manual effort. Huffman pointed out that the challenge is less about the math and more about assembling the inputs. “It is just about the challenge of pulling all that, centralizing it and getting it formatted in a way that you can actually do the math,” he said.
That complexity makes a methodical approach essential. Gaps in data can disrupt the process, and while assumptions can be used to fill those gaps, they need to be clearly documented as part of the reporting methodology.
Precision also matters. Using exact material weights where possible leads to more accurate reporting and can help brands better understand where costs are coming from. By contrast, relying too heavily on averages or estimates can introduce uncertainty, especially as reporting requirements become more detailed over time.
Tips and tricks from early reporting
Drawing on early reporting experience, Huffman outlined practical steps to stay on track. Planning ahead is essential, with teams encouraged to map out deadlines and assign responsibilities early in the process.
Analyzing packaging portfolios can also reveal opportunities to reduce costs through eco-modulation. Adjustments such as increasing recycled content or simplifying material structures can have a direct impact on fees. Equally important is building systems that support ongoing reporting. EPR is not a one-time exercise, and data will need to be updated regularly as packaging and regulations change.
Huffman also pointed to common missteps, including delaying eligibility assessments or waiting until the last minute to begin data collection. Missing steps in the sequence can lead to higher costs or lost opportunities for incentives.
A cross-functional challenge
EPR compliance requires coordination across multiple functions, including packaging, supply chain, finance, sustainability, and legal. Huffman noted that many companies are still determining where responsibility should sit internally.
“This information lives in so many different places,” he said, emphasizing the need for clear communication and collaboration.
Without alignment, the process can stall. Teams may not understand what data is needed or why it matters, leading to delays and incomplete reporting. Huffman encouraged companies to be deliberate in how they communicate requests and to provide context for stakeholders who are new to EPR.
Moving from awareness to action
The webinar closed with a focus on execution. EPR is already being implemented, with reporting cycles underway and additional states preparing to launch programs.
For CPG brands, the priority now is building a repeatable process that can keep pace with evolving requirements. The work is detailed, and the timeline is tight, but Huffman’s guidance emphasized steady progress.
Approached step by step, with attention to sequence and coordination, the process becomes more manageable. Like the analogy Huffman returned to throughout the session, success depends on getting the steps in the right order and keeping everything moving in sync. PW
