EPR packaging reporting requirements: California, Colorado and Oregon

In California, Colorado and Oregon, producers register with Circular Action Alliance (CAA), sign the state addendum, and then submit full supply reports through CAA's producer portal. The data starts at the component: its material, weight and reporting category for each SKU.

Five steps

1. Register with CAA and sign the state addendum for each state you sell in. CAA says this comes before any report.
2. Collect one row per SKU and component with material, weight and unit. The free CSV template lists the fields the industry group marks as required in each state.
3. Give every component the reporting category of the state it sells in. For Oregon, see how to pick the category.
4. Close the gaps before you report. Missing weights come first in the problems consultants describe.
5. Enter the data in CAA's workbook or portal. The format is CAA's, not ours, and we have not seen it.

PackGap checks a SKU file for missing weights and conflicting values. The first 25 SKUs are free, the 30-day pass is $149, and the file stays in your browser.

Questions people ask

When is the EPR packaging report due?

The latest dates we found are from Holland & Knight on April 10, 2026: full reports of 2025 supply data for California, Colorado and Oregon were due May 31, 2026. We did not find the next due date on a public official page, so check CAA's producer portal instead of relying on this page.

Do EPR reports need data per packaging component?

The industry group's requirements list (Sustainable Packaging Data Council, version 2, January 6, 2026) marks component code, quantity, weight, weight unit, majority material class and majority material as required in all three states. CAA's own workbooks are portal-only and we have not seen them.

Is there a simplified way to report?

Holland & Knight describes simplified reporting, with broader material categories, for Minnesota, Maryland and Washington. California, Colorado and Oregon use full reporting.

What has happened with the California program plan?

CalRecycle's program page says CAA submitted its producer responsibility plan on October 13, 2026 and that CalRecycle has 75 days to review it. CAA's 2027 California fee schedule is preliminary and non-binding until the plan is approved.

Does PackGap file the report for me?

No. PackGap checks your SKU file for missing weights, unit errors and conflicting values before you report. The report itself goes in CAA's format.

Sources

Opened on November 8, 2026. Programs change, so check the source before you rely on it.

• Holland & Knight: Are You Ready to Report Your Packaging Data Next Month?, April 10, 2026
• Sustainable Packaging Data Council (industry group): US EPR Data Requirements for California, Colorado and Oregon, v2, January 6, 2026
• CalRecycle: Packaging EPR program page (CAA plan received October 13, 2026)
• Circular Action Alliance: 2027 California Producer Fees Schedule (preliminary and non-binding until the program plan is approved), October 1, 2026
• Circular Action Alliance: 2027 Oregon Producer Fees Schedule, October 1, 2026
• Circular Action Alliance: 2027 Colorado Producer Dues Schedule, October 1, 2026

Related: EPR packaging data template, incomplete packaging weights, Oregon EPR reporting categories: how to pick one for each component.