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EPR cover Image

EXTENDED PRODUCER RESPONSIBILITY (EPR) FOR PACKAGING

Extended Producer Responsibility (EPR) for packaging brings a new level of complexity for organizations. EPR reporting requirements in the US and Canada mean organizations need to gather accurate data across their supply chains, often from multiple sources that haven’t previously been tracked in detail. Compliance costs are also starting to reflect the recyclability and material choices behind each product, putting added pressure on procurement and design teams.

Extended Producer Responsibility (EPR) for packaging has a direct impact on how products are designed, how materials are sourced, and how costs are managed over time. Organizations that stay on top of EPR reporting requirements are better placed to stay compliant and avoid unnecessary cost.

GET HELP WITH EPR COMPLIANCE
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WHAT EPR FOR PACKAGING MEANS FOR YOUR ORGANIZATION

Extended Producer Responsibility for packaging moves the cost and responsibility of packaging waste onto the organizations that place it on the market. This increases focus on end-of-life impacts, recyclability, and material recovery, transferring attention from the manufacturing and use stages to what happens once packaging becomes waste.

If your organization manufactures, imports, distributes or sells packaged goods, you may be required to:

  • Understand your EPR reporting requirements

  • Collect detailed data on packaging materials and formats

  • Submit accurate reports to the relevant authority or Producer Responsibility Organization (PRO)

  • Pay fees based on material type, volume and recyclability

This means EPR compliance directly impacts costs, operations and packaging design decisions. 

Without the right approach, businesses risk:

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Cost Leakage

Overpaying due to poor data or duplicate classifications.
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Reporting Gaps

Missing reporting obligations.
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Process Inefficiency

Inefficient internal processes.
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Compliance Risk

Fines or compliance issues

HOW TUNLEY'S EPR ASSESSMENT HELPS REDUCE COSTS

In states with Extended Producer Responsibility (EPR) laws for packaging, fees are increasingly eco-modulated based on recyclability, post-consumer recycled (PCR) content, and other sustainability attributes. Producer Responsibility Organizations (PROs), such as the Circular Action Alliance, set material-specific fees that reflect actual end-of-life management costs. 

  1. Easily Recyclable Packaging (e.g. mono materials aligned with state collection lists and APR Design® Guide criteria) typically qualifies for lower base fees and potential eco-modulation discounts or bonuses.

  2. Hard-to-Recycle Formats (e.g. multi-layer films, certain pigmented plastics, or materials not widely collected/sorted) face higher fees.

  3. Additional incentives often reward higher PCR content, source reduction, reusability, or lower toxicity.

Tunley's EPR services help organizations navigate this state-by-state landscape with packaging assessments, redesign recommendations, data reporting support and strategies developed by expert PhD-level Scientists.

 

This structure incentivizes better design. The more recyclable and sustainable your packaging, the lower your exposure to EPR fees in states where programs are active (e.g. California, Colorado, Oregon, Maine, Minnesota, Maryland, Washington, and with more states following). 

Key benefits of proactive EPR assessment and optimization:

  • Identify opportunities to shift from high-fee formats to widely recyclable designs
  • Maximize eco-modulation incentives (bonuses for PCR, recyclability, etc)
  • Reduce overall compliance costs as programs expand and fee schedules mature in 2026 and beyond
  • Prepare for state-specific reporting on packaging data (material, weight, format and recyclability characteristics)
EPR Product Manufacturing

FIND OUT HOW MUCH YOU COULD SAVE UNDER EPR

Our team of Sustainability Consultants and PhD-Level scientists are on hand to help your business with EPR for packaging reporting. 
REDUCE COSTS WITH EPR

OUR EPR DATA COLLECTION AND REPORTING SERVICE

Tunley Environmental is an environmental sustainability consultancy, using science-based methodologies to support organizations with EPR data collection and reporting services. Our PhD-level scientists help you stay compliant, avoid overpayments and identify opportunities to reduce packaging fees through better data and smarter design.

Tunley provides end-to-end packaging EPR consultancy, helping you meet your obligations with confidence and accuracy so you can stay compliant and pay the lowest possible fees. More than a packaging data reporting consultancy, we use tried and tested methodology that makes compliance simple and cost-effective.

Our EPR Compliance Service Includes:

1
EPR Obligation Assessment

We help you understand how EPR regulations apply to your business by reviewing your products, packaging and market activity, so you can confidently determine your reporting obligations. 
2
Packaging Data Collection & Structure

Full organization of your packaging data, including materials, weights and classifications.
3
Data Validation & Quality Assurance

Systematic review to ensure accuracy, completeness & readiness for submission.
4
Submission-Ready Templates

Prepared for US Producer Responsibility Organizations.
5
Tools & Training for future reporting

Enabling your team to manage EPR reporting requirements independently across future years, locations or states. 

DOES YOUR BUSINESS NEED TO REPORT UNDER EPR FOR PACKAGING?

Our team of Sustainability Consultants and PhD-Level scientists are on hand to help your business with EPR for packaging reporting. 
GET EPR COMPLIANT TODAY

Tunley Environmental has been great support through our carbon assessments. Tunley completed an embodied carbon report on one of our products, we used the embodied carbon report and submitted to MAKE UK sustainability regional awards and won for our region. Great to be working with Tunley and the team and look forward to reaching our goal of net zero which I know we can with the support and expertise of the team.

Scott Commons

HSQE Manager | PB Design

Everything was provided as agreed and to a great standard. Very pleased with the work that Tunley Environmental undertook for us.

Adam Samuel

Director | Capchar

Tunley Environmental have been acting as a supporting partner in research and development of Optima Products Ltd NZC strategy to reduce energy, reduce embodied carbon and improve sustainability credentials, by the assistance of technical knowledge and experience inputs on material science, energy calculations, including thermal heat loss to improve our production heat insulation design, and valued steering on electrochemical coating systems.

Gracie Stammers

Environmental & Sustainability Assistant | Optima Products Ltd

The project ran seamlessly from carrying out regular communication between key project stakeholders to the speed of the project execution and completion. We would highly recommend Tunley Environmental to companies looking to complete product LCAs.

Keely Warren

Brand & Communications | Tremco

They did exactly what was asked and where we had less than perfect understanding of the issues involved their expertise showed through. The response time to follow up enquiries was excellent and I would happily use Tunley again.

Michelle Smith

Intellectual Property COntroller | Power Roll

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HOW WE DELIVER EPR COMPLIANCE

Our approach to EPR data collection and reporting services is structured, repeatable and tailored to your operating markets across the US and Canada. The core steps stay the same for any location; we tailor the details, deadlines and submission route to the jurisdictions where you operate.

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END-TO-END EPR DATA COLLECTION

We support your organization with end-to-end EPR data collection and reporting services, ensuring you have complete, accurate and packaging data ready for submission.

This includes assistance with:

  • Defining your reporting scope across all products placed on the market

  • Identifying unique packaging types across your product range

  • Building detailed packaging data, including materials, components and weights

  • Calculating total material quantities in line with EPR reporting requirements

  • Supporting registration and submission to the relevant authority or Producer Responsibility Organizations (PRO)

  • Preparing and submitting your supply report for the baseline year

  • Providing tools and templates for future EPR reporting.

OUR SCIENCE-BASED APPROACH

Our science-based approach, led by PhD-level scientists, ensures your packaging data is robust, accurate and compliant.

We will assist your organization to:

  • Gather a full list of products sold, distributed or imported into your chosen market

  • Identify packaging types based on material, structure and composition

  • Develop a detailed bill of materials using supplier data or our own analysis

  • Break down each packaging type into components, weights and material categories

  • Calculate precise material quantities in the required formats and units

  • Register and report with necessary bodies, such as the Circular Action Alliance US. 

A packaging type is a unique combination of materials, structure and composition. If multiple products or SKUs share identical packaging, it is counted as one type only.

For example, a beverage company selling cola, lemonade and orange soda in the same 330ml aluminum can with the same label and cap = one packaging type. 

COMPLIANCE SIMPLIFIED

Our expertise ensures your data is accurately structured, validated and analyzed, giving you visibility into your packaging profile. This creates a strong foundation for identifying cost drivers and exploring opportunities to optimize packaging and reduce future EPR fees as schemes mature.

Our structured and methodical approach delivers:

  • Accurate, submission-ready data that meets EPR reporting requirements

  • Reduced risk of errors, fines or overpayments

  • Streamlined internal processes, reducing your team’s workload

  • Long-term capability through tools and templates

  • Confidence in your EPR compliance, supported by an award-winning, science-based consultancy

We don’t just provide EPR reporting help, we build systems that make compliance repeatable, efficient and cost-effective. You only pay per unique packaging design, not per SKU. Accurate classification can significantly reduce EPR costs. Most manufacturers manage between 5 and 30 packaging types, depending on product variety. Bottles, pouches, cans, boxes, wrappers, labels and multi-layer films may each count separately if they differ. 

GET A TAILORED QUOTE BASED ON YOUR PACKAGING TYPES, DATA COMPLEXITY AND REPORTING NEEDS

Our team of Sustainability Consultants and PhD-Level scientists are on hand to help your business with EPR for packaging reporting. 
REQUEST A QUOTE

FRAMEWORKS AND METHODS WE FOLLOW

Tunley delivers EPR for packaging support in line with the key regulations, frameworks and reporting requirements relevant to your market. Our methodology stays consistent across jurisdictions, while the reporting requirements, deadlines and submission routes are tailored to the jurisdictions where you operate.

Our team applies a science-based approach to ensure your packaging data aligns with the requirements of each framework while also identifying opportunities to improve recyclability, reduce waste and lower future compliance costs.

We support organizations in line with frameworks including:

 

 

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RELEVANT PRODUCER ORGANISATIONS
Registration and reporting routes through relevant Producer Organisations, including Circular Action Alliance.
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APR DESIGN® GUIDE FOR PLASTICS RECYCLABILITY

They key industry-standard tool for assessing and improving packaging recyclability in the US (widely references in EPR compliance and eco-modulation).
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OREGON EPR
Oregon’s EPR program can increase costs, but eco-modulation incentives can help reduce fees through improved packaging and data.
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MAINE STEWARDSHIP PROGRAM FOR PACKAGING
Producers must register with a state-approved PRO, report data and begin fee payments in scheduled phases.
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COLORADO PRODUCER RESPONSIBILITY FOR STATE-WIDE RECYCLING ACT
Registration, reporting and fee payment obligations are being phased in.
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CALIFORNIA PLASTIC POLLUTION PREVENTION & PACKAGING PRODUCER RESPONSBILITY ACT (SB 54)
Producers must work towards major reductions in single-use plastic packaging and improved recyclability or composability.
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MINNESOTA PACKAGING WASTE AND COST REDUCTION ACT
Producers must register, join a PRO and meet phased reporting and sustainability requirements.
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MARYLAND PACKAGING AND PAPER PRODUCT EPR
USA Enacted with reporting and compliance timelines that will extend into later 2020s.
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WASHINGTON STATE EPR LEGISLATION
Producers must improve solid waste management – USA PRO to be appointed and producers required to register and comply mid-2026 onward.

WHY CHOOSE TUNLEY FOR EPR PACKAGING

Tunley is not a typical EPR compliance consultancy, other consultants stop at data entry. We bring carbon scientists who understand both the rules and the science behind recyclability scores. Our independent LCA reviews give you evidence that cuts fees. We have delivered significant emission reductions and compliance for manufacturers across sectors. You get expert guidance, not just a form filler.

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01PhD-LEVEL SCIENTISTS

Our PhD-level scientists guide your data collection process, going beyond compliance to identify opportunities to reduce waste, improve efficiency, cut emissions, and lower costs.

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025-STAR SERVICE

100% 5-star feedback from global clients

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03SCIENCE-BASED FEE REDUCTIONS

Our LCA work supports fee reductions that pure data firms cannot. In states with eco-modulation, such as Oregon, this can directly reduce your fees. We turn compliance data into real savings.

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04CROSS-SECTOR EXPERIENCE

From mining to engineering, construction and manufacturing to pharmaceutical.

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05SYSTEMATIC REVIEW

We provide structured templates and a rigorous internal review process to ensure data accuracy and completeness, along with guidance through submission via direct upload or manual portal entry.

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400 OVER 400 ASSESSMENTS GLOBALLY
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FREQUENTLY ASKED QUESTIONS

What is Extended Producer Responsibility for packaging?

It is a regulatory approach that requires businesses to take responsibility for the environmental impact of their packaging, including reporting data and contributing to waste management costs.
Do I Need to Comply with EPR reporting requirements?

If your business places packaged goods on the market, you may need to comply depending on thresholds and jurisdictions.
What data is required for EPR reporting?

Typically the data required for EPR reporting is: material types, weights, packaging formats and quantities placed on the market.
What counts as a packaging type in EPR for packaging?

A unique combination of materials and design. Identical packaging across multiple products is counted once.
Can EPR costs be reduced?

Yes. Through better data, improved packaging design and science-based analysis, businesses can reduce fees, particularly in eco-modulated systems.
How does the EPR reporting process work?

We help you gather and structure your product and packaging data, classify packaging types, calculate materials quantities, and prepare submission-ready reports in line with regional EPR requirements. We also support registration and guide you through submission to the relevant authority or Producer Responsibility Organization (PRO).