Packaging EPR is not really a filing problem. It is a packaging-data operations problem dressed as a filing problem — and once a producer is obligated in two or three states, the submission becomes the smallest part of the chain.
The filing itself is often the easy part.
Producers who have gone through their first U.S. packaging EPR cycle tend to describe the same surprise: the submission portals work, the report templates are knowable, and the calculation logic, once set, is fairly mechanical. What is hard is the operational work that has to happen before any of that becomes possible.
Packaging EPR is not really a filing problem. It is a packaging-data operations problem dressed as a filing problem. Once a producer is obligated in two or three states, with annual reporting cycles, SKU-level component data, supplier-sourced specifications, methodology documentation, and reconciliation against prior years, the regulatory submission is the last and smallest step in a chain that touches procurement, packaging engineering, sustainability, finance, legal, and sometimes IT.
This article is about why that chain is harder to build than it looks, why spreadsheets and software each solve only part of it, and why a managed service model has emerged as the most practical operating arrangement for many producers — not as an ideological position, but as a structural one.
Most producers underestimated, going in, how much of EPR compliance has nothing to do with regulations at all.
The G&A Institute, which advises companies on sustainability reporting infrastructure, put it directly in a 2026 packaging-data preparation guide: "This may be the most significant operational challenge of EPR packaging compliance, simply because companies have likely never had to track, collect, or report such data before." Their analysis adds, almost in passing, that "packaging information is scattered across procurement, operations, and product management functions."
That second sentence is the real one. Before a producer can file an annual supply report, it has to know — at the SKU level, with component weights, material types, recyclability status, and recycled content — what it actually sold. For most producers, that information has never been assembled in one place, in a consistent format, with documented provenance. It has been managed for entirely different purposes: cost negotiation, design specification, regulatory labeling, sustainability disclosure. Each function holds a fragment.
The work of EPR compliance, then, starts well before the report. It starts with whether the underlying packaging data exists in a usable form. For most producers, the honest answer is: not yet.
The fragmentation is not accidental, and it is not a sign of organizational dysfunction. It is what happens when a category of data is operationally important to several functions but governance-owned by none.
Rob Kaszubowski, a practitioner who has written about EPR infrastructure design, describes the typical state of affairs: "CAD drawings may be buried in a PLM system. Procurement may track supplier material data. Sustainability may own recycled content and recyclability claims. And regulatory teams often manage compliance manually in spreadsheets. And the volume breakouts of 'what products' and 'how much' of each product and respective packaging type is tracked in a separate ERP system."
The same pattern shows up inside companies that, from the outside, look highly organized. Brie Seferian, senior manager for EPR in North America at Mondelēz International, described her own company's situation at a 2026 Sustainable Packaging Coalition conference: "Everyone's in a different system." Acquisitions over the years had brought in different platforms, different schemas, different conventions. Teams were "hunting down old spreadsheets and PDFs."
Specright's Alex Clark made a sharper observation at the 2025 Packaging Recycling Summit: brands do not, in many cases, own their own packaging data. Suppliers do. "Bringing suppliers into your spec data process becomes an essential part of a successful EPR strategy."
This is the operational reality EPR walks into. Most brands were not built around packaging-level reporting governance. They were built around moving product. The data exists, but in pieces, owned by different people, defined differently, and updated on different cadences.
The first response to an unfamiliar reporting obligation is almost always a spreadsheet. This is reasonable. Spreadsheets are flexible, fast, and cost nothing. For a single-state filing in year one, with a stable SKU list and a single team owning the work, a spreadsheet is often adequate.
The spreadsheet breaks structurally, not gradually, when the reporting becomes recurring, multi-state, SKU-level, and methodology-sensitive. Recyda, an EPR data platform, described the transition with unusual clarity: most EPR calculations "are being done by spreadsheets or manual logic-based systems. This approach requires manually mapping complex EPR rules into formulas, leaving room for human error and consuming significant time and resources." The next sentence is the important one: "The problem intensifies when regulations and fees change, requiring you to make tedious calculation adjustments, or, even worse, discard previous work and start the entire process over."
Spreadsheets do not maintain methodology consistency across reporting periods. They do not carry an audit trail. They do not flag when a packaging specification changes upstream. They do not catch when a supplier's recycled content claim has been silently revised. And they concentrate institutional knowledge in whoever built them.
Seferian, again, named the dependency risk directly: companies need their systems integrated "where we don't all have a panic attack when somebody leaves."
Spreadsheets are not wrong. They are simply not the right operational substrate for a recurring, multi-jurisdiction, audit-exposed reporting obligation.
The clearest moment in which EPR reveals itself as a data operations problem is the historical baseline.
California's SB 54 framework requires producers to file a 2023 baseline report — packaging data from three years prior — that will be used to measure source-reduction progress against 2032 targets. The baseline is a regulatory anchor: every future reduction is measured against it. For a producer that did not maintain structured, SKU-level packaging data in 2023, this is not a reporting task. It is a reconstruction project.
SC Johnson's experience, described publicly by the company's packaging sustainability lead, illustrates the scale of the work. The company had been voluntarily reporting packaging data to the Ellen MacArthur Foundation since 2019, which made it relatively well-positioned. Even so, Oregon's first reporting cycle required them to go back, physically weigh packaging, and rebuild the underlying database, because the state's requirements differed from the voluntary disclosure framework. "That's the hardest part, honestly, in terms of the amount of time that we spend."
Most producers do not begin from SC Johnson's starting point. They begin without a centralized packaging dataset of any kind, and with the historical baseline year already three years behind them. The work is not optional, and it cannot be deferred — the baseline is what every subsequent year's report is anchored to.
This is the moment when the framing of EPR as a filing exercise breaks down. You cannot file what does not yet exist.
Once producers understand that the data is the problem, the natural next step is to look at purpose-built EPR software. There are now several capable platforms — Lorax EPI, Specright, Assent, Source Intelligence, Recyda, and others — that can centralize packaging specifications, apply jurisdictional fee logic, generate compliant submission files, and provide an audit trail. These platforms are genuinely useful, and for producers with mature internal data processes, they materially reduce reporting friction.
What they do not do — and what their own documentation is careful not to claim — is remove operational ownership of the underlying data.
Lorax EPI, one of the most established EPR reporting platforms in the U.S. market, is unusually explicit about this. In its Software-Only service tier, the producer "retains responsibility for: data collection and preparation; data management and analysis; generating, verifying and submitting reports." The platform organizes the work; the producer does it. Lorax's separate Outsourced Compliance tier exists precisely because many producers, having tried the software-only model, concluded they needed help with the work the software does not absorb.
Other vendors describe the same retained-operations gap, even if less directly. Assent's EPR product is built around supplier engagement at scale, because — as the company notes — "without scalable supplier engagement, fragmented data collection leads to costly reporting errors." That is an acknowledgment that the producer still has to run the supplier-engagement process; the software helps it run faster.
PwC, advising clients on EPR implementation, said something similar in plainer language: "Don't underestimate the challenge of aggregating data across locations, systems or from various suppliers." Software changes how that aggregation is done. It does not change who is responsible for doing it.
This is the central reason "we'll just buy software" is an incomplete answer. Software organizes a workflow. It does not, on its own, create the underlying data, validate it, maintain it across packaging revisions, or govern the methodology decisions that determine whether the data is defensible.
The single-state version of this problem is manageable. The multi-state version is qualitatively different.
A producer obligated in California, Oregon, and Colorado now operates against three distinct material taxonomies, three reporting calendars within roughly a month of each other, and — for California alone — multiple concurrent report types, including a retroactive baseline and a forward-looking source-reduction plan running through 2032.
The Circular Action Alliance, the producer responsibility organization administering most of these programs, has built its portal infrastructure around exactly this multi-report reality: data preparation workbooks, upload templates, and validation checks, organized state by state. That infrastructure exists because the underlying obligations cannot be served by a single annual data pull.
Each new state added does not increase the work linearly. It increases the cross-jurisdictional reconciliation surface. The same SKU may be classified differently in different states. The same supplier-provided weight may need different allocation logic. The same packaging change may need to flow into multiple reports on different timelines.
Once a producer has three or more active state obligations, EPR has stopped being a filing task. It is an operating model — and maintaining recurring reporting readiness across packaging revisions and multiple jurisdictions becomes the actual deliverable.
A managed EPR service is not an alternative to software. It is a response to the gap between what software does and what compliance actually requires.
The logic is structural rather than promotional. If the recurring operational work — supplier data requests, gap analysis, methodology documentation, packaging-revision tracking, state-by-state reconciliation, baseline reconstruction — sits with the producer in a software-only model, then producers face a build-or-buy decision about that operational capability itself. Building it internally requires hiring, training, and retaining specialized staff across compliance, packaging, and supplier-engagement functions, and absorbing the personnel-continuity risk Mondelēz named directly. Buying it means contracting with a service provider who maintains that capability across many clients and amortizes the expertise.
For producers whose core business is not packaging-data governance — which is most of them — the build option is increasingly hard to justify. Hiring for an internal EPR operations function in 2026 is hiring into a regulatory landscape that will continue to expand for several more years, with a thin pool of practitioners who have actually run a full multi-state cycle, and against deadlines that are not patient.
A managed service does not eliminate the producer's responsibility. The producer still signs the report and remains legally accountable. But the operational chain — collecting data from suppliers, validating it against jurisdiction-specific taxonomies, maintaining methodology consistency, surfacing exceptions, sustaining recurring reporting readiness, preparing submission packets — can be run by a counterparty whose institutional purpose is to run it.
This is why managed EPR services have begun to emerge as a distinct category, separate from both software and traditional compliance consulting. The market is not consolidating around a single tool. It is sorting into a layered model: software where structured data already exists, services where the data work itself has to be done, and increasingly, integrated offerings that combine both.
Orbitlex was built around this operating reality. We do not treat packaging EPR as a filing task to be automated. We treat it as a recurring packaging-data operations function — one that has to produce defensible reports each year, withstand PRO and state validation, and stay current as products, suppliers, and regulations change.
Our engagements typically follow four stages. A Free Compliance Status Check tells a producer where they actually stand: which states they are obligated in, what data exists, what is missing, and what the realistic compliance posture looks like. An EPR Compliance Blueprint converts that assessment into a sequenced plan with methodology decisions documented and a state-by-state obligation map. A Packaging Data Audit builds the reporting-ready packaging inventory at the component level — material, weight, and EPR/CAA classification per state — so the data underneath the reporting layer is structured and defensible. Managed EPR Compliance runs the operating model from there — Year 1 includes initial registration, state portal setup, and the first reporting cycle as Year 1 setup work, and the subscription continues through annual reporting, regulatory monitoring, eco-modulation support, and Term-matched past-due backfill in the years that follow.
For some producers, that full sequence is the right fit. For others, only one or two stages are. The decision is operational, not ideological: how much of this work does it make sense to own internally, and how much should be run by a counterparty whose entire focus is running it well.
The filing itself, in the end, is often the smallest part of the problem. The question worth asking is whether the rest of the chain is built to last.
Orbitlex runs the packaging-data operations chain — supplier engagement, methodology consistency, state-by-state reconciliation — that makes recurring multi-state EPR reporting routine.
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.