You cannot report historical packaging data that was never systematically maintained — you can only reconstruct it. CA SB 54's 2023 baseline is the clearest example. Reconstruction is a different category of work than annual reporting.
The report may be due in 2026. The packaging data may be from 2023.
Most producers think they are preparing a filing. Many are actually rebuilding a historical record.
That three-year gap is where many producers discover that EPR is not, in the way they assumed, a reporting obligation. It is a reconstruction project. California SB 54 fixes 2023 as the baseline year against which every future source-reduction measurement will be calibrated through 2032. Oregon and Colorado required first-cycle reporting of prior-year supply data before any structured EPR data system had been built. The first reporting cycle in each of these states is, in effect, an exercise in recovering packaging data that was never collected with this reporting in mind. As multi-state EPR programs mature, reconstruction is emerging as its own operational cost center — separate from reporting, separate from software, and separate from ongoing compliance operations.
You cannot report historical packaging data that was never systematically maintained. You can only reconstruct it.
The most common assumption producers carry into their first EPR cycle is that the data exists somewhere. Products were sold, invoices were issued, packaging existed, suppliers maintained specifications. Surely the records can be retrieved.
The reality, as practitioners are now publicly describing it, is more difficult. The data was not collected for EPR purposes — it was collected for procurement, design, manufacturing, and finance, each function recording the parts of the packaging story it needed and ignoring the rest. Historical packaging specifications are often scattered across PLM systems, supplier emails, archived PDFs, ERP records, and spreadsheets maintained by individuals who have since left the company.
The G&A Institute, in a 2026 guidance document on EPR data preparation, captures this without softening: companies "have likely never had to track, collect, or report such data before." The framing is precise.
The challenge is not that the past was lost. The challenge is that the past was recorded for different purposes.
The EPR-required form of it — at the level of component weight, material composition, and recyclability status — was rarely the form that any function had reason to preserve.
Historical availability and historical accessibility are different things. A producer can know that 2023 packaging existed, sold, and was invoiced, and still find that no single record contains the information that an EPR baseline report requires.
Annual EPR reporting, once the data is in hand, is a workflow problem. The work involves classifying packaging components against jurisdictional taxonomies, calculating weights and fees, formatting submissions, and meeting deadlines. It is procedural. It scales with software.
Reconstruction is a different category of work entirely. It begins not with a dataset to be processed, but with an absence to be addressed. The work resembles forensic investigation more than compliance administration: locating physical packaging or supplier records, inferring weights and compositions where measurement is no longer possible, validating estimates against secondary sources, normalizing inconsistent formats into a single defensible framework, documenting methodology decisions for audit, and standing behind the result with traceable provenance.
Reporting begins with a dataset. Reconstruction begins with an absence.
The shift from one type of work to the other is not a difference of degree. It is a difference of category — different inputs, different labor profile, different skill mix, different cadence, and different output. A producer that prepared to do reporting and discovered, partway in, that it was actually doing reconstruction has not encountered a harder version of the same task. It has encountered a different task.
California's SB 54 is the single most consequential driver of historical reconstruction in U.S. packaging EPR, because it permanently anchors every future source-reduction measurement to a fixed historical year: 2023.
H2 Compliance summarizes the structural permanence directly: "The targets will always apply against the 2023 baseline, regardless of the company's growth." The statewide reduction targets — 10% by 2027, 20% by 2030, 25% by 2032 — are all measured against the same 2023 starting point.
When SB 54 was signed in 2022, no producer had an obligation to collect packaging data in EPR-compliant form. The first reporting portals opened in late 2025. The baseline year therefore predates by two to three years any systematic EPR-purpose data collection. Every California-obligated producer must now reconstruct what it placed on the California market in 2023 — component by component, weight by weight — from procurement records, supplier specifications, sales data, and, in some cases, physical measurement of remaining samples.
The financial consequences of getting this wrong are not contained to the baseline year. Holland & Knight, in its May 2026 advisory on the final SB 54 regulations, states the dependency plainly: "Accurate baseline reporting is essential, as it directly shapes the fee rates applied in subsequent periods and establishes the producer's individual source reduction starting point." rePurpose Global puts the same point in operational language: "Errors here compound for six years."
Every future reduction claim depends on the credibility of the baseline it is measured against. The baseline is not, in any meaningful sense, a disposable compliance artifact. It is the foundation for six years of financial and regulatory exposure.
The clearest indication that reconstruction is a structural problem, rather than a discipline gap, comes from the producers who began with the strongest sustainability programs.
SC Johnson, a Founding Member of the Circular Action Alliance, had been voluntarily reporting packaging data to the Ellen MacArthur Foundation and the Consumer Goods Forum since 2019. By any reasonable measure, the company arrived at Oregon's first EPR reporting cycle better prepared than most. Even so, Jeff Bezzo, SC Johnson's executive director of plastic and packaging sustainability, described the experience publicly in 2025: "So we had to go back… and actually started to weigh packaging and do all that exercise and create a database."
The detail matters. SC Johnson did not refresh an existing dataset. It physically weighed packaging components to populate a newly built database, because its existing voluntary-reporting infrastructure did not capture data in the form Oregon's program required. Bezzo also noted that the company's existing system "didn't pull data from all business units" — including brands acquired in the prior five years — and that scope expansion during Oregon's rulemaking forced retroactive revisits of packaging categories the company had not originally included.
SC Johnson's experience matters because it removes the simplest explanation: lack of preparation.
Mondelēz International described a parallel reality at a 2026 Sustainable Packaging Coalition conference. Brie Seferian, the company's senior manager for EPR in North America, described teams "hunting down old spreadsheets and PDFs" across acquired businesses, each of which had been maintained in a different system. "Everyone's in a different system," she said. "We need better data — all of us."
If companies with mature sustainability programs had to reconstruct data, the challenge is not a lack of effort. It is the nature of the requirement itself. The form of data EPR now requires was not the form any prior framework — voluntary or mandatory — asked for. The gap between what was tracked and what must now be reported is structural, and it cuts across company size, sustainability maturity, and industry sector.
The prior article in this series argued that EPR software does not eliminate the packaging-data work that sits beneath the reporting layer. Reconstruction is the most acute version of that argument.
EPR reporting platforms — Lorax EPI, Recyda, Specright, Source Intelligence, and others — are designed to organize data that exists, structure it against jurisdictional taxonomies, and produce defensible reports. The Lorax EPI ENVI platform "automatically calculates your reports based on your product and packaging data." Recyda's workflow begins, in its own product documentation, with "Consolidate Data" — bringing together data from fragmented systems. Both descriptions presuppose that the data exists to be consolidated.
Where historical specification data was never recorded — where a packaging weight was never captured, where a coating was never listed in a BOM, where a label's material composition was never formally documented — no platform can supply it. Packaging Dive's California component-tracking analysis states the point plainly: "This level of detail often doesn't exist in current ERP systems or procurement databases."
Software can structure historical data. It cannot manufacture historical evidence.
The relevant vendors themselves describe the boundary. Lorax EPI offers "average / generic BoM creation" as a discrete service offering, because generic bills of materials are substitutes for historical specifications that no longer exist. Anthesis offers "proprietary uplift methods" to complete datasets where supplier responses are missing. These are not flaws in the platforms — they are explicit acknowledgments that reconstruction sits upstream of what reporting software does, and that the gap has to be closed by human-executed work or statistical substitution before any reporting workflow can begin.
Reconstruction has a cost structure of its own, distinct from the cost of preparing and submitting an annual report. The activities are operational, sequential, and labor-intensive:
supplier outreach and follow-up; archived specification review; packaging inventory creation and BOM rebuilding; physical weighing where supplier records are unavailable.
It also includes data normalization across inconsistent formats, scope determination against state taxonomies, methodology documentation for audit defensibility, gap-filling through uplift or generic-BOM substitution, and data recovery from acquired brands whose records sit in legacy systems.
Each activity carries its own time cost. Source Intelligence has described sourcing packaging weights from suppliers as work that "can take months." rePurpose Global documented a representative case: more than 200 suppliers contacted, 60 percent responded after two months, and roughly half of the responses contained usable data. Anthesis describes the supplier survey process as consuming "valuable hours" that distract from strategic work. None of this happens inside a software workflow. All of it precedes one.
These costs do not belong to annual reporting. They belong to reconstruction.
That distinction is what makes reconstruction a cost center rather than a line item. It has its own labor profile, its own vendor categories, its own timeline, and its own deliverable — the assembled, validated, defensible historical dataset. The reporting cost is what shows up in the report. The reconstruction cost is what shows up before the report can exist.
The third distinction worth naming is between reconstruction and ongoing compliance — because they look alike from a distance and behave differently in practice.
Reconstruction is backward-looking. It addresses data from prior calendar years that was never collected in EPR-compliant form. It is finite: once a baseline is established or a prior year's supply data is recovered, that specific reconstruction project is complete. Its output is data creation — records that did not exist before. Its labor profile is dominated by human activities: outreach, investigation, measurement, validation, documentation. It cannot be automated, because the work is closing a gap that no system has the inputs to fill.
Ongoing compliance is forward-looking. It addresses current-year packaging data as products are made, sold, and tracked. It is recurring: every reporting cycle runs against the same operating model. Its output is data maintenance — keeping records current as suppliers, packaging, and regulations change. Its labor profile is dominated by process: workflows, governance, supplier relationships, methodology consistency. Increasingly, it can be partly software-enabled, once the data foundation exists.
This distinction is operationally important because it determines what kind of capability a producer should build or buy. Reconstruction calls for project-shaped engagements — defined scope, finite timeline, custom methodology, evidence-building as the deliverable. Ongoing compliance calls for an operating model — recurring cadence, maintained foundation, integrated workflows. Confusing the two leads to predictable mistakes: trying to retrofit a reporting platform onto a reconstruction problem, or treating reconstruction labor as an operating cost that will repeat indefinitely. Neither approach matches the actual shape of the work.
Reconstruction is the entry cost of a system that was not built early enough. Ongoing compliance is what runs once the foundation is in place.
Orbitlex treats reconstruction as a distinct workstream rather than a filing task. The objective is to establish a defensible historical dataset, complete the initial reporting cycle, and transition producers into a maintained operating model.
The framing matters because reconstruction is not, in our view, a service that should be sold off a price card. It is custom-scoped work, sized to the specific gap between what a producer has and what the regulation requires. What matters is not the price tier. What matters is that reconstruction is recognized as its own category of work, with its own labor, its own timeline, and its own deliverable — and that the next cycle starts from maintained data, not reconstructed memory.
The goal is not simply to complete the baseline. The goal is to ensure the next baseline never has to be reconstructed.
It is the data that should have been collected three years ago. Orbitlex scopes Packaging Data Reconstruction as a distinct workstream — not a service tier — and transitions producers into a maintained operating model after the baseline is built.
Get Free EPR Compliance CheckThis article is for informational purposes only and does not constitute legal advice. Regulatory timelines and program requirements are subject to change. Always verify current obligations with state authorities, PROs, and qualified legal counsel directly. Orbitlex is not a law firm.