What six state packaging EPR programs actually require in 2026

Published 2026-09-15 · Pack Reporting

Extended producer responsibility for packaging stopped being a West Coast curiosity in 2026. Six states now run producer reporting under the Circular Action Alliance framework, and they all landed on the same first deadline: May 31, 2026.

The reports themselves are not legal arguments. They are data. States want packaging weights by material type, broken down to the SKU or component level in California, Colorado and Oregon. That means your bill of materials, your supplier specs and your shipment volumes all have to agree with each other.

Oregon has already named roughly 300 producers it considers noncompliant. Washington required registered-PRO membership starting July 1, 2026. The direction is one way: more states, more data, real fees.

What to do this quarter

Map your active assortment to packaging components, assign each a material and weight, and reconcile it against shipment data into each state. That table is the report. Everything else is formatting.