EPR Data Management: How to Overcome Compliance Reporting Challenges in 2026 and Beyond

After going through the process of Extended Producer Responsibility (EPR) reporting in Oregon, Colorado and California in 2025, companies are discovering that compliance is not only a legal challenge but also a data management challenge. Four additional states: Maine, Maryland, Minnesota and Washington, will require reporting starting in 2026, introducing further complexity around data collection and structure. If your organization is struggling to gather the right information, track the correct metrics or build internal support for EPR initiatives, you're certainly not alone.

The good news? With a structured approach and guidance, these challenges become entirely manageable and can offer insights into potential cost reductions and business improvements.

The Top EPR Data Management Challenges Producers Face Today

Organizations tackling EPR compliance, often for the first time, encounter a few primary obstacles that can feel overwhelming without a clear strategy in place.

Fragmented Data Systems: The No. 1 Barrier to Accurate EPR Compliance Reporting

One of the most common frustrations we hear from clients is the sheer difficulty of gathering required EPR data from disparate systems. Sales data lives in one platform (purchase order software, point-of-sale systems or accounting software) product and packaging specifications in another, such as product lifecycle management (PLM) software or a supply chain and procurement platform, and secondary and tertiary packaging information might exist only in vendor contracts or spreadsheets scattered across departments. This kind of fragmentation creates a significant barrier to efficient reporting, requiring manual data collection that is time-intensive, prone to errors and often more costly.

EPR Reporting Data Gaps: What Producers Don't Know Can Cost Them

Perhaps even more challenging is uncovering that certain data points required for EPR reporting have never been tracked historically. Particularly under California's Senate Bill 54 (SB 54), information gets as granular as the amount of plastic ink used in a product's packaging or the weight of the tape used to seal a cardboard box. Many companies never had a business reason to document such specific details about packaging materials, weights or post-consumer recyclability that EPR programs now demand. The fact that these gaps exist is not a reflection of any operational shortcoming; often it is simply that these data points were never a necessity for business success.

EPR Fee Forecasting: How to Budget When Final Fee Structures Aren't Set

Adding another layer of complexity, companies are struggling to forecast and budget for EPR fees with any degree of confidence. Unlike other compliance costs that carry predictable patterns, EPR fees vary by state, material type and tonnage. In many cases, the final fee structures haven't even been fully established yet.

Finance teams are asking reasonable questions: What should we budget for next fiscal year? How do we forecast costs when we're still determining our packaging footprint? What happens if regulations change?

These conversations are happening across departments, with procurement, finance, sustainability and legal teams all seeking clarity that's difficult to provide. Without accurate forecasting, companies can't properly allocate budgets, evaluate the financial impact of packaging decisions or have productive internal conversations about compliance strategy. This financial ambiguity makes it challenging to secure the executive buy-in and resource allocation that successful EPR programs require.

Overcoming Internal Resource Constraints and Building EPR Program Buy-In

Finally, even when companies recognize what needs to be done, they often lack the time, dedicated resources or internal leadership buy-in to move forward. EPR compliance competes with a vast array of business priorities, and without executive sponsorship or clear ownership of the process, initiatives often stall before even beginning.

Building a Good Faith EPR Compliance Strategy: Progress Over Perfection

If you're reading this and feeling the weight of these or any other challenges related to the EPR process, it's important to remember that many companies are in the same position. What matters most right now isn't perfection; it's a demonstrated good-faith effort to report as accurately as possible and implement systems to set up your organization for success in the future.

Many organizations, including several of our clients at Clearyst, are in this data organization and management phase. In our opinion, this is exactly where the focus should be. The companies that will be most set up for success are not necessarily the ones with the most resources; they're the ones that take deliberate, thoughtful steps toward setting up systems and processes for the long term. These companies will not only be well prepared for any new state EPR compliance, but will have the data structure in place to drive a more comprehensive analysis of the business by identifying problem areas, risks and opportunities to make business improvements.

This is where working with experienced partners becomes a real value add. At Clearyst, we provide blueprints for approaching the EPR reporting process as well as organized data templates to bring structure to what can feel like an overwhelming task. These frameworks will help your company track down the right data points, prioritize collection efforts, identify any data gaps and create scalable, repeatable processes not just for today's reporting but for the years ahead.

While it's obviously important to ensure near-term compliance, we advise our clients to take a long-term view for the future state of EPR by establishing systems and processes using the strategies below.

How to Build EPR Data Infrastructure That Scales With New State Requirements

There's no way around the upfront work required to get internal systems purpose-fit for EPR reporting. You'll need to engage relevant internal stakeholders, most importantly those from the IT department, to evaluate your current data architecture, identify integration opportunities and potentially modify how information flows through your organization.

That being said, the resource investment will certainly pay dividends down the line, not only in terms of time savings but also cost savings opportunities in the form of EPR fee reductions and rebates identified through data analysis. As more states implement programs and reporting requirements move from one-time projects into annual obligations, having robust data infrastructure will be table stakes.

The key is collecting EPR-relevant data at the point of origin. Gather materials weights in your PLM system. Modify purchase orders to capture packaging specifications. Implement new fields in your enterprise resource planning (ERP) system. Instead of working retrospectively to reconstruct data months later when reporting deadlines loom, work with internal stakeholders to get systems configured accordingly.

Why California's SB 54 Should Be Your EPR Data Reporting Baseline

California's EPR regulation, SB 54, is the most detailed in the United States, requiring data at a level of granularity that many other states don't yet mandate. In our estimation, using California as a baseline for your company's EPR reporting is a sound strategic approach. If your data infrastructure and collection processes are set up to meet California's standards, your organization will be able to flexibly accommodate reporting requirements across multiple jurisdictions. As other states implement new programs or update existing ones, your organization will have the systems in place to ensure compliance.

EPR Fee Scenario Planning: A Smarter Approach to Compliance Budgeting

The financial forecasting challenge requires a different approach than traditional budgeting exercises. Companies waiting for finalized information that may not arrive until well into the compliance cycle are left in limbo; forward-thinking companies are adopting scenario-based planning models. This means developing multiple budget projections based on different assumptions about packaging volumes, material compositions and potential fee structures across jurisdictions.

Leverage final fees in states with EPR programs in place, such as Oregon, as a benchmark for budgeting purposes in other states. Create low, medium and high cost scenarios to establish reasonable budget ranges and build in contingency planning that protects the organization from unexpected fee announcements. Working with EPR advisers who have insights into emerging fee structures and Producer Responsibility Organization (PRO) rate-setting processes can significantly improve the accuracy of these forecasts. Additionally, conducting a thorough packaging audit as fees are finalized allows companies to model different scenarios based on their actual usage of covered materials. This proactive approach facilitates more productive internal conversations across departments and demonstrates to executives that EPR costs can be managed strategically, not just absorbed reactively.

EPR Advisory Support: How Expert Guidance Reduces Compliance Risk

Finally, one of the most critical elements of maintaining a strong EPR strategy is staying informed. Regulations are evolving rapidly. Updates occur regularly, and new states passing legislation include variations in program goals, covered materials and the scope of reporting requirements. What's compliant today might be insufficient tomorrow, and what's required in one state might differ significantly in another.

One of the biggest value drivers that we hear from clients is their ability to cut down hours per week listening to educational webinars, reading the latest legislation and researching shifting timelines and reporting changes that may impact their organization. This is where advisory support moves from helpful to essential. At Clearyst, our dedicated EPR consultants monitor regulatory developments across all jurisdictions, interpret how changes impact different business models and help your company adapt before deadlines arrive. Focus on your core business responsibilities by leveraging specialists who make it their full-time job to stay ahead of the curve.

Moving Forward With Confidence: Your EPR Data Management Action Plan

Extended Producer Responsibility represents a significant shift in how companies must think about packaging and product stewardship. Data management challenges are real, but they're not insurmountable. To get ahead, determine where your organization currently stands, take steps to organize your data systematically and prepare for an increasingly complex regulatory environment.

Whether you're just beginning to understand your obligations or already knee-deep in data collection, remember that progress is the goal. Build the foundation thoughtfully, align your systems with the most rigorous requirements and don't hesitate to seek expert guidance when the path forward isn't clear.

EPR is here to stay, and it's only going to expand. The question isn't whether to prepare, but how quickly you can equip your organization with the tools and systems to turn challenges into operational strengths.