Seller Guide

Packaging EPR Checklist
for Amazon Sellers

Four determinations. Three operations. Seven items. The full Amazon-seller compliance map, in order.

7 min read · July 2026

You're an Amazon seller. You've heard about packaging EPR — maybe from a CalRecycle letter, maybe from Twitter, maybe from your legal team asking questions.

Here's the full checklist, in order, from “am I in scope?” to “my compliance is running.”

Seven items. The first four are determinations you make once. The last three are operations you run every year.

Four determinations. Three operations. Seven items. That's the whole map.

Phase 1 — Determine Your Obligations

Four items. All decisions, not operations. Do them once, then act on the results.

1.Are you a producer?

The producer under California SB 54 and every other US state's packaging EPR law is the party whose brand is on the package. Not Amazon. Not your co-packer. Not your 3PL. You, if your brand's on the label.

Three archetypes:

  • Private-label seller / DTC brand extending onto Amazon: you're the producer.
  • Reseller of others' brands: generally not the producer for those products (brand owner is), but any private-label SKUs of yours are still yours.
  • Importer of a foreign brand: you're likely the producer under tier-2 or tier-3 of the definition, if the foreign brand owner isn't in the state.

Done when: you can name your archetype and know whether the producer definition applies to you, per state.

Common mistake: assuming Amazon handles this because you use FBA. It doesn't (in the US). See the two pieces below for the full reasoning.

See also: Does California SB54 Apply to Amazon FBA Sellers? for the three-tier producer definition; Amazon FBA vs FBM: Who Is the Producer? for the fulfillment-channel question.

2.Which states are you in scope for?

Seven US states currently have active packaging EPR laws: California (SB 54), Oregon (SB 582), Colorado (HB22-1355), Maryland (SB 901 amending Env. § 9-2501), Minnesota (Packaging Waste and Cost Reduction Act), Washington (Recycling Reform Act, E2SSB 5284), and Maine (LD 1541).

You're in scope for a given state if you sell (or ship) covered material into it. Multi-Channel Fulfillment (MCF) counts too — if Amazon fulfills a Shopify order into California, that unit is a California sale for your EPR purposes.

Tip: Use the ship-state field in your Amazon All Orders Report to see which states your products actually reach.

Done when: you have a per-state answer for whether you have sales volume into each of the seven.

Common mistake: treating low-volume states as “not applicable.” Most states have small-producer exemptions, but the exemptions aren't automatic — see Item 3.

3.Are you exempt?

Most states have a small-producer exemption. California's is under $1 million in gross in-state sales, per PRC § 42060(a)(5)(A). Other states have similar thresholds, usually revenue-based.

The exemption is not self-executing. You don't get it by being small. You get it by registering with the state (via the PRO) and submitting an exemption application. Approval is discretionary. Even if you're clearly under the threshold, you're not “exempt” until you've documented it and been approved.

Also: exempt producers still have some residual obligations — California's 2032 recyclable and compostable design requirement (PRC § 42050(b)) applies regardless of exemption status.

Done when: you've either (a) applied for and received an exemption in every state where you qualify, or (b) confirmed you don't qualify and are proceeding as a regular producer.

Common mistake: treating the exemption as automatic. If you think you're “under the threshold and therefore fine,” you're not. You're non-compliant with the registration requirement until you file the exemption paperwork.

See also: Does California SB54 Apply to Amazon FBA Sellers? §5 for the California exemption mechanism.

4.Which PRO(s) do you register with?

A Producer Responsibility Organization (PRO) is the industry-run body that collects producer data and administers program operations on behalf of the state. Which PRO applies to you depends on which state you're in scope for.

As of July 2026:

  • Circular Action Alliance (CAA) is the sole PRO for California, Oregon, Colorado, Maryland, Minnesota, and Washington.
  • Maine has not yet selected a stewardship organization — the state's Department of Environmental Protection has delayed its Request for Proposals for the SO contract. If you're in scope for Maine, monitor Maine DEP for updates.

If you're in scope for any of the six CAA states, one CAA registration covers you across all of them. Maine, when it lands, will likely be separate.

Done when: you've registered with CAA (for whichever of the six states apply to you) and — if you're in scope for Maine — you're monitoring Maine DEP for stewardship-organization selection.

Common mistake: delaying registration because “the deadlines are still moving.” The registration prerequisite isn't moving. It's independent of when the recurring reporting cadence gets finalized.

Phase 1 ends here.

If you've completed these four determinations, you know:

  • whether you're a producer;
  • where you owe;
  • whether you're exempt;
  • who you report to.

What follows isn't about deciding anymore. It's about operating.

The determinations are yours. The operations don't have to be.

Phase 2 — Operate Your Compliance Program

Three items. All ongoing operations, not one-time decisions. This is where compliance actually gets fulfilled.

5.Collect packaging data (per SKU)

For every SKU you sell into any of the seven states, you need a complete packaging dataset: per-component material class and form, per-component weight, per-component recyclability status (via the applicable Covered Material Category or CMC), PCR content where applicable, and unit counts by state.

This is not a report you download. It's a mapping you build — SKU by SKU, component by component. For most producers this work does not yet exist inside the business; nobody has ever had a reason to build it before.

Done when: every SKU shipped into any in-scope state has a complete packaging spec that maps components to CMC categories, and unit counts per state are reconciled against Amazon reports.

Common mistake: waiting until the reporting deadline to start. SKU inventory, spec collection from co-packers and suppliers, and CMC classification take months, not days.

See also: How to Pull State-Level Packaging Data Out of Amazon Reports for EPR walks through exactly what Amazon reports give you and what they don't — this is the input side of Item 5.

6.Aggregate and submit to your PRO

Once the per-SKU dataset exists, aggregate it: total weight per CMC per state, plastic component count per state, disposition data where required.

Then submit to your PRO. CAA has its own producer-facing submission timeline that runs ahead of state agency deadlines (the state agency deadline is the PRO's deadline to the state, not yours to the PRO). California's regulation at 14 CCR § 18980.10.1 sets July 1 as the annual data report deadline the PRO owes CalRecycle; CAA's producer submission deadline is earlier. Other states are finalizing their reporting calendars — check the CAA producer portal for current dates.

Done when: the year's aggregated data is submitted to CAA (or the applicable PRO) on their producer-facing timeline, with per-state breakdowns intact.

Common mistake: assuming the state agency deadline (e.g., CA July 1) is your deadline. It's the PRO's deadline to the state — the PRO needs your data earlier to prepare the aggregated filing.

7.Maintain audit-defensible records

Records are a throughout obligation, not a post-filing archive. They start during Item 5 (data collection) and continue past Item 6 (filing) for as long as the state's retention window requires.

What that means practically: for every packaging weight, material classification, PCR content claim, or methodology decision you've reported, there's a source document behind it. Supplier spec sheet, co-packer packaging drawing, PCR certification from a materials vendor, internal engineering log, purchase invoice. Retrievable. Attributable. Auditable.

Both CAA and state agencies can request substantiation. They can request it before you file, during the filing period, or years after — anywhere inside the retention window.

Done when: every reported figure has a retrievable source document, records are organized so an auditor could trace any number back to its origin without help from you, and the retention window for each state is being met.

Common mistake: treating records as something you build after the report goes in. If your records only cover the current cycle and don't include the decisions and sources behind them, an audit request will find gaps you no longer have time to fix.

What to do with this

Phase 1 is a set of decisions you can complete in a couple of weeks, provided the information isn't spread across seven consultants.

Phase 2 is an ongoing operation — packaging-data engineering, PRO submission on the right timeline, and audit-defensible recordkeeping — that runs every year for as long as your products are on the market in an EPR state.

If you want to check what NOT to do first: Common Amazon Seller Mistakes Under Packaging EPR — six assumptions Amazon sellers commonly walk in with, each with the correction.

If you want a fast confirmation of where you stand on Phase 1

In about five minutes, a free Compliance Status Check tells you your producer status per state, whether you qualify for the small-producer exemption, and what PRO registration you need. Phase 1 collapsed into a five-minute answer.

Start a Free Compliance Status Check

If you'd rather not run Phase 2 yourself: that's what Orbitlex operates — end to end, every year.

Related Orbitlex Services
EPR Status Check →Free: Phase 1 answered — producer status, exemption, PRO registration. Managed EPR Compliance →Phase 2 operated for you — data, submission, records, every year.