Amazon tells you where products went. EPR requires you to know what packaging went with them — and that second data model is where the work is.
You got a letter, or an email, or a heads-up from a colleague. California SB 54, or Oregon, or Colorado. You have packaging EPR obligations now. You need to report something about the packaging your products ship in — down to weight, material, and state.
You went into Amazon Seller Central and pulled a report, hoping it would have what you need.
It doesn't. Not really.
You downloaded the All Orders Report and got tens of thousands of rows with SKUs, quantities, and ship-to states. Useful data. But nothing about what any of that packaging weighs, what it's made of, or how California wants it classified. Then you Googled “amazon sales report by state for EPR” and found nothing that answered your actual question.
This article is about what's actually going on — and what to do next. The short version: Amazon gives you where products went. EPR requires you to know what packaging went with them. Those are two different data problems, and the second one is where most of the work is.
Before you start pulling data, confirm you're the producer at all: Does California SB54 Apply to Amazon FBA Sellers?
Before we get to Amazon, it helps to understand what regulators are actually asking you to produce.
The specifics vary by state. California's SB 54 is the most detailed, but Oregon, Colorado, Maine, Maryland, Minnesota, and Washington all have their own versions. Since California's requirements are the clearest and the most operationally involved, we'll use them as the reference throughout this article. The other six states work the same way in shape; the categorization details differ.
Under California SB 54, once a year (starting 2026, due July 1), you submit a report to Circular Action Alliance — the industry-run organization California picked to collect all this data. For each type of packaging material you sold into California in the previous calendar year, you report four things (14 CCR § 18980.10.2):
“That material” isn't just “plastic” or “paper.” California uses a list of 95 specific categories — Covered Material Categories, or CMCs. Each CMC combines a material class (Glass, Ceramic, Metal, Paper and Fiber, Plastic, or Wood and Other Organics) with a specific type and form. Rigid plastic bottles are one CMC. Flexible plastic film is another. Corrugated boxes are another. And so on, 95 times.
Oregon works similarly. Colorado works similarly. Each state has its own program and its own annual report. Six of the seven states — California, Colorado, Oregon, Maryland, Minnesota, and Washington — run through the same producer responsibility organization, Circular Action Alliance (CAA); Maine runs through a separate Stewardship Organization (SO) that has not yet been selected. But the shape of the ask is the same everywhere: material weights, by category, by state.
That's the target output. Everything below is about how you get from Amazon's data to that output.
The right report to start with is the All Orders Report. Not the FBA Fulfilled Shipments Report (which is FBA-only). Not the FBM Order Reports (which are seller-fulfilled only). The All Orders Report is the one that combines both, so it's the right file to reach for whether you fulfill through Amazon, ship yourself, or both.
Where to find it: In Seller Central, go to Orders → Order Reports → All Orders tab. Pick a date range and download.
What's in it (the default 37 columns): for every order line item, the report gives you:
amazon-order-id, purchase-date, order-status, fulfillment-channel (Amazon = FBA, Merchant = you shipped it), sales-channel (Amazon.com, or Non-Amazon if you're using Multi-Channel Fulfillment for Shopify or other stores).product-name, sku, asin, item-status, quantity.ship-city, ship-state, ship-postal-code, ship-country.item-price, item-tax, shipping and promotion fields, plus a few B2B and export-related columns.What this gives you for EPR: you can filter by ship-state = CA (or OR, CO, MD, ME, MN, WA), get your California unit sales by SKU, and know exactly which SKUs went into which states in which volumes.
That's real, useful, jurisdictional data. It answers the “where did my products go” question completely.
Look back at that 37-column list. Now compare against what the EPR annual report actually wants. Amazon does not give you:
One important clarification: Amazon Multi-Channel Fulfillment orders count too. If you use Amazon warehouses to fulfill Shopify orders (visible in the report as sales-channel = Non-Amazon or Non-Amazon US), those units shipped into California still count toward your California EPR obligation. The obligation follows the packaging that ends up in California — not the marketplace it was sold on.
The mismatch you're bumping into is not a bug in Amazon's reporting. It's the shape of the problem itself.
Amazon reports live in transaction data — orders, prices, addresses, fulfillment status. EPR reports live in material data — weights, materials, categories, disposition. Those are two different data models. Neither one can be trivially derived from the other.
You cannot compute a CMC classification from an ASIN alone. You cannot infer a component weight from a purchase price. There is no algorithm that turns “1 unit of SKU-1234 shipped to Los Angeles” into “34.2 grams of rigid PET in Covered Material Category P-05.” The mapping between them lives outside the Amazon data entirely.
That mapping is the work.
The information you need — the packaging weights, materials, and category assignments — is somewhere. It's just not in Seller Central. Depending on how your business is set up, it lives in some combination of:
Most sellers, when they actually sit down to inventory this, find one of three situations. Best case: the spec sheets exist somewhere and just need to be tracked down and normalized. Middle case: some SKUs have specs and some don't — you'll need to fill the gaps by weighing samples or contacting old suppliers. Worst case: the co-packer changed years ago, the old records are gone, and you're rebuilding from scratch.
Any of these is manageable. None of them is what you were hoping Amazon would just hand you.
Here is the actual flow, end to end, from the moment Amazon ships a unit to the moment California knows about the material.
In an Amazon context, Stage 1 is the All Orders Report (sku, quantity, ship-state); Stage 2 isolates California sales; Stage 3 totals SKU-level units for the year; Stage 4 looks up each SKU's packaging spec (box, mailer, inserts, labels); Stage 5 breaks each component down to material class, form, and weight per unit; Stage 6 matches every component to one of CalRecycle's 95 Covered Material Categories; and Stage 7 aggregates total weight per CMC plus plastic component count, submitted to CAA by July 1.
Look at where Amazon actually appears in this pipeline.
Amazon only participates in Stage 1. Everything after that belongs to the producer.
Some stages are fast. Filtering to a state (Stage 2) is a straightforward filter. Computing SKU-level units (Stage 3) is arithmetic. Submitting the aggregated data (Stage 7) is a form.
The slow work lives in Stages 4 through 6: getting spec sheets, deconstructing each SKU's packaging into components, and classifying each component into California's category system. This is why “just pull the Amazon report” doesn't feel like it made anything easier. It didn't move you closer to any of the slow stages.
A note on doing this for the other six states: the fundamental data movement — transaction → jurisdiction filter → SKU → spec → component → category → aggregated report — is universal. But the specifics differ. Six of the seven states run through the same producer responsibility organization — Circular Action Alliance — each under its own statute, categories, and annual report (Oregon's, for example, under ORS 459A.869). Maine runs separately through a state Stewardship Organization that has not yet been selected. You build the underlying pipeline once, then adapt its outputs to each state's reporting framework.
Amazon gets a lot of attention in this article because it's where you started looking. But the same pipeline applies if you sell through Shopify, Walmart Marketplace, your own DTC site, wholesale into brick-and-mortar retail, or via EDI feeds to distributors. Every one of those channels is a transaction data source. None of them tells you what your packaging is made of.
Amazon gives you the transaction history. Packaging EPR requires a packaging-data model layered on top of that history. That layered model — the SKU-to-spec-to-component-to-CMC mapping — is what a producer is being asked to build.
For many producers, this model does not yet exist inside the business. The state regulator is often the first party to require this information in a standardized, reportable form. Building it is what compliance actually looks like at the operational layer.
The transaction-data source may change. The packaging-data model does not.
This is exactly what Orbitlex operates for producers. We take your transaction data on one end. We hand you a defensible California and multi-state EPR filing on the other. Everything in between sits with us.
In about five minutes, a free Compliance Status Check tells you which states you have obligations in, which producer tier you're in, and roughly what the packaging-data model would take to build.
Start a Free Compliance Status Check