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Here’s what retailers learned the hard way from new packaging EPR deadlines

Most retailers still talk about Extended Producer Responsibility (EPR) as something that happens to their vendors: A CPG brand misses a filing, a supplier scrambles to reclassify a material, a buyer gets looped in only when a compliance question holds up a purchase order.

Two reporting cycles ago, that was a reasonable way to think about it. But then May 31, 2026 arrived, and six states —California, Colorado, Oregon, Minnesota, Maryland and Washington — all required producers to file Annual Supply Reports on the same day, the first time multiple state EPR programs have converged on one deadline. A lot of retailers found out last minute how much of the reporting obligation was actually theirs.

Before your next planning cycle, four things are worth confirming:

  • Whether your private-label lines make you the producer of record;
  • What packaging data you’re requiring from vendors and in what
    format;
  • Whether e-commerce and fulfillment packaging is explicitly built into your compliance plan; and
  • How your footprint maps against every state with an active EPR program.

Here’s what retailers learned the hard way from new packaging EPR deadlines | Chain Store Age

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