10 min read · May 2026
Three states use the phrase "simplified" to describe their 2026 packaging supply reports. The word creates a false impression about how much internal work is required to produce one.
Maryland, Minnesota, and Washington each require a Simplified Supply Report due May 31, 2026. Relative to California, Oregon, and Colorado — which require full material-category reporting under live fee structures — the simplified format is narrower. Fewer material categories. No per-component plastic counts. No fee calculation attached to the submission.
Core Thesis
Simplified Supply Reporting reduces the external filing format. It does not reduce the internal data work required to produce a defensible report. The categories are fewer. The underlying reconstruction is the same.
The simplified format was designed for pre-program states — jurisdictions where regulatory infrastructure is being built but fees are not yet calculated from submitted data. Compared to a full supply report, it requires fewer material categories, no plastic-component-level counts, no PCR content disclosure, and no recyclability classification. The submission interface is less detailed. The number of line items is smaller.
What it does not simplify: producers must still identify every covered SKU sold into the state, assign each packaging component to the correct material category, determine verified component weights, and multiply by state-level supply volume. The output is shorter. The work behind it is not.
Maryland, Minnesota, and Washington each require a Simplified Supply Report covering 2025 calendar-year data, due May 31, 2026 via the CAA producer portal. All three programs are pre-fee — no immediate financial obligations attach to this report — but that changes as each program matures. These submissions are expected to inform the agency baseline for how much covered material each producer introduced to market, and are likely to influence future fee calibration, enforcement priorities, and program design. The figure submitted in 2026 is not a draft.
Minnesota's registration deadline of July 1, 2025 has already passed. Producers not yet registered with CAA are late. The simplified supply report is still due May 31, 2026, but producers submitting without having registered may be classified as delinquent under CAA's compliance framework — a status that, if unresolved, could result in escalation to the state regulator.
Brands encounter the simplified submission interface and assume the data collection behind it is similarly reduced. It isn't. A brand with several hundred SKUs across retail, Amazon, and DTC may discover that no single internal system contains the packaging data required to produce a defensible report. To file accurately, a producer must work through four questions that exist regardless of reporting format:
CAA permits producers without state-level sales data to use a population-based apportionment fallback: a state's allocated share of national supply equals its share of U.S. population. If Washington represents approximately 2.3% of U.S. population, a brand without state data would report that 2.3% of national packaging supply was introduced there.
This methodology is available. It is also a trap. Most brands do not distribute proportionally to population — they sell through regional retailers, focused D2C geographies, or distributors with concentrated footprints. Population ratios overstate volume entering states where a brand has limited or no presence, and therefore overstate fee liability once fee programs activate. More importantly, CAA has signaled that reliance on apportionment will be strongly discouraged as programs mature. Producers using it in 2026 are building a first-year baseline they will eventually need to reconcile against accurate data — a reconciliation that is harder retroactively than it would have been to resolve correctly in the first cycle.
Apportionment Is a Fallback, Not a Default
A first report built on apportionment is a first report that carries forward inaccuracy — compounding as each subsequent year layers on top of it. When fee programs activate in Maryland (2028–2029), Minnesota (2029), and Washington (2030), the fees will be calibrated against this baseline.
"The hardest part of simplified reporting is not the filing. It is the reconstruction — building packaging data that most brands have never needed to maintain before."
Material classification is where the gap between what brands think they know and what they actually have on record becomes visible. A coffee pouch is not "plastic" — it is a multi-layer laminate combining foil, polyethylene, and nylon. A juice carton is not "paperboard" — it is paper combined with polyethylene and sometimes aluminum. Each of these requires assignment to a specific reporting category. Misclassification produces an inaccurate report.
The information required to make those classifications — material composition by layer, resin type, coatings — lives with packaging suppliers, not inside brand ERP systems. Supplier outreach to collect material composition data takes time. For brands with large SKU counts across multiple suppliers, that collection alone can span weeks. Brands that begin the reporting process in early May are starting too late.
Maryland, Minnesota, and Washington are pre-fee states today. No immediate financial obligation attaches to the simplified report. That changes. Maryland's fee structure is expected to activate before July 1, 2028. Minnesota's full program is expected to begin in early 2029, scaling producer funding from 50% to 90% of program costs by 2031. Washington's full program is expected to begin January 1, 2030. In each case, future fee structures are likely to be informed by the reporting baseline being established now.
What Brands Underestimate
That "simplified" refers to the submission format, not the underlying data work
That the first report is likely to serve as the agency's baseline for future fee calibration
That supplier outreach for material composition data takes weeks, not hours
That a simplified report can be selected for CAA Verification Audit — and must be substantiated in full
CAA's Producer Compliance Policy (Version 1.0, February 2026) establishes a Verification Audit process. Producers may be required to provide packaging data, supplier documentation, sales volume records, and methodology documentation to support submitted figures. A simplified supply report does not receive simplified audit treatment. If a Maryland, Minnesota, or Washington report is selected for verification, the full underlying dataset must be provided: which SKUs, which components, which weights, which sales volumes, which supplier documentation.
If the report was built from population estimates and rough classifications, there is no documentation to produce — because the methodology did not generate any. The safest simplified report looks simple from the outside and is thoroughly documented on the inside: supplier specification sheets, state-level sales records or documented apportionment methodology, packaging bill of materials, and classification rationale for any multi-material item.
Brands subject to simplified reporting in Maryland, Minnesota, and Washington are frequently the same brands already subject to full reporting in California, Oregon, and Colorado. The 2026 reporting cycle is not three simplified filings and three full filings — it is six concurrent obligations, all due May 31.
The underlying packaging dataset is largely the same across all six states. But each report requires a different extraction pass: California uses 95 material categories and a separate state portal; Washington uses simplified categories via CAA. The brands that handle this most effectively built a unified packaging data infrastructure first, then ran each state's report as an output of that infrastructure. The initial investment is real. The annual maintenance cost drops substantially once the foundation exists.
The timeline is compressed. The right work, prioritized correctly, is still executable.
Maryland, Minnesota, and Washington share the May 31 deadline with California, Oregon, and Colorado. For brands with obligations across both groups, the simplified states do not move to the back of the queue. Brands that have focused exclusively on California or Oregon preparation are approaching May 31 without having started on the simplified states — a common pattern, and the one that turns "easier" filings into last-minute crises.
Simplified supply reporting is not where EPR compliance gets easy. It is where EPR compliance gets started — for states that will eventually impose the same operational requirements as California, once their programs mature.
The brands that use 2026 to build defensible packaging data infrastructure will enter future fee cycles with a structural advantage. The ones that treat the first simplified report as a form fill will spend the next three years reconstructing data under fee pressure instead of maintaining it.
Orbitlex identifies your covered states, reconstructs the packaging dataset required for a defensible report, and handles the submission.
Get Free EPR Compliance CheckThis article is for informational purposes only and does not constitute legal advice. Reporting requirements, deadlines, exemption thresholds, and state program structures are subject to change; verify current obligations with the applicable PRO, state agency, and qualified legal counsel. Orbitlex is not a law firm.