Multi-state producers face a quiet but costly trap in the packaging EPR pre-program phase. Minnesota, Maryland, and Washington currently accept a simplified supply report built on aggregated 2025 material weights, while California, Colorado, and Oregon demand SKU-level and component-level detail. Teams that misread that difference either over-report, misapply state-specific scoping rules like Minnesota’s “personal, noncommercial use” limit, or miss Circular Action Alliance registration entirely and lose access to the reporting portal. The compliance stakes are real: enforcement sits with state agencies, late filings carry exposure, and the data you submit now feeds program planning and early fee setting in Washington. This analysis breaks down exactly what simplified packaging EPR reporting requires, how it differs from full reporting, and how to assemble packaging data once so it survives the transition to detailed, fee-bearing reporting later.
