Operating at Scale: How Enterprise Teams Put EPR into Motion

Running EPR for one market is a compliance project. Running it for ten - or fifty - is an operating model. Once your company moves beyond one or two markets, the challenge shifts from “what do we have to report?” to “how do we make this part of our daily routine? ”

At scale, you’ll need five things:

• A clear RACI (a responsibility matrix that clarifies who is Responsible, Accountable, Consulted, and Informed) and accountable business owners;
  
• Repeatable processes that align with reporting calendars;
  
• A systems backbone that can trace packaging from GTIN (the Global Trade Item Number that uniquely identifies every product and packaging level) to shipment;
  
• Structured supplier collaboration; and‍
• A KPI and dashboard layer that keeps teams in control of both compliance and cost.

Three quick anchors:

• UK: Packaging EPR now requires producers to collect and submit detailed packaging data and pay fees based on that data - guidance updated July 9, 2025 (GOV UK)
  
• EU: The Packaging and Packaging Waste Regulation (PPWR) took effect on February 11, 2025, tightening obligations on design, labeling, and recycled content (Ropes & Gray).‍
• US: Seven states have passed packaging EPR laws - California, Colorado, Oregon, Maine, Minnesota, Maryland, and Washington - with the Circular Action Alliance (CAA) serving as the approved producer responsibility organization (PRO) in several of these states, including Colorado and California.(Circular Action Alliance).

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Roles and RACI: Who Does What

EPR operations run best when ownership is explicit.

Executive sponsors - usually in sustainability, operations, finance, or compliance/legal - own targets, budgets, and risk. The global EPR lead turns strategy into an operating rhythm: one playbook, many markets.

Each business unit or brand owns the accuracy of its packaging data - weights, materials, components - while local compliance leads handle registrations, filings, and payments to PROs. In several U.S. states, that means working through the CAA, the PRO; in the EU, through national compliance schemes.

Master data teams maintain the GTIN hierarchy, ensuring every “each,” “inner,” “case,” and “pallet” aligns with GS1 standards. Procurement plays its part by collecting supplier declarations and post-consumer recycled (PCR) content proofs. Finance forecasts and reconciles EPR fees, making them part of normal financial planning.

When mapped to a simple RACI chart, it’s clear: compliance sits with the market teams, but accuracy begins upstream with packaging design and data governance.

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Process: From Pack Spec to Fee Payment

Most large producers follow six steps - repeated across markets:

1. Author and approve packaging data.  Record every packaging component, from film to closure, and keep it current. Even small changes can shift a SKU’s fee category.
   
2. Validate recycled content and design attributes.  Capture PCR % certificates and “designed-for-recyclability” claims from suppliers. These are already required under the EU’s PPWR and will likely influence U.S. state fee modulation too.
   
3. Map sales and shipments to territories. Link product masters to sales data by country or state to calculate the total weight of packaging placed on the market.
   
4. Apply market-specific rules. Feed that data through a rules engine that reflects each jurisdiction’s thresholds, categories, and fee tables. The UK uses weight-based fees; California’s SB 54 and Colorado’s HB 1355 require producers to fund collection and recycling through a PRO.
   
5. Submit, pay, and archive. File data and fees on schedule - annually in most U.S. states, biannually in the UK - and store proof of submission. Regulators may require records for seven years or more.‍
6. Feed lessons back into design. Use fee impact data to flag expensive materials or packaging formats, then work with R&D and suppliers to design for lower cost and higher recyclability next time.
   

The goal is rhythm: a quarterly or semi-annual process that feels as routine as financial reporting.

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Building a Scalable Systems Backbone 

At enterprise scale, managing EPR through spreadsheets stops working. You need connected systems that can turn packaging data into reliable, reportable insights. Here’s what that typically looks like in plain English:

• Product lifecycle tools (PLM/PIM): These are the databases where product and packaging specifications live  -  what each SKU looks like, what it’s made of, how much it weighs, and how it’s packaged. Think of them as the “single source of truth” for your packaging information.
  
• Enterprise Resource Planning (ERP) systems: This is where you track what’s been sold, in which markets, and in what quantities. Connecting ERP sales data to your packaging data lets you calculate how much packaging has been “placed on the market”  -  the foundation for EPR reporting.
  
• Supplier platform: A shared portal (even a structured SharePoint or SaaS tool) where suppliers upload the paperwork you need  -  like recycled-content certificates, material declarations, or notifications of packaging changes. It keeps your sourcing data clean and auditable.
  
• Rules engine: A software layer that applies the right regulations and fee schedules for each market. For example, it knows that California’s EPR rules are different from the UK’s and calculates fees accordingly. Updating a regulation shouldn’t mean rebuilding your system  -  you just update the rule.‍
• Central data hub (“data lake”): A secure, cloud-based storage area that brings all of this information together - packaging specs, sales data, supplier declarations, and regulatory rules - so teams can analyze, track changes over time, and create dashboards. You don’t need to know the technology; just think of it as a master folder where all your EPR data lives and updates automatically.
  

In short: one place for what you sell, one for what it’s made of, one for where it’s sold, and one layer that connects the dots for reporting.

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Working with Suppliers

Suppliers are both your data source and your first line of defense. Standardize what you ask for: a single materials and components template aligned to GS1 attributes, with fields for polymer type, coatings, labels, and PCR %.

Include EPR clauses in supplier contracts: timelines for data submission, obligations to provide certificates, and mandatory change-notification windows when packaging specs change.

Some brands even share dashboards showing how supplier materials influence EPR fees - a powerful way to co-design for eco modulation,  lower costs and higher circularity.

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Measuring What Matters

EPR reporting generates a mountain of data  -  but in the right hands, that data becomes a management tool. It tells you not just what you owe, but how your packaging is performing, where costs are creeping up, and how close you are to your circularity goals.

The most effective companies don’t treat EPR reports as a once-a-year compliance exercise. They build or subscribe to ongoing dashboards that turn regulatory data into business intelligence that reveal trends, hotspots, and opportunities to design smarter.

Here’s what those metrics look like in practice:

Compliance metrics measure whether your reporting system runs smoothly and on time.

• On-time submission rate (target ≥ 99 %)‍
• Data completeness - the share of SKUs with full packaging, material, and supplier data
  

Financial metrics show how EPR costs affect your bottom line.

• EPR fee forecast vs. actuals by market and material
• Fee intensity  -  EPR cost per kilogram sold or per dollar of revenue
  

Circularity metrics connect your EPR data to your sustainability ambitions.

• Average post-consumer recycled (PCR) content across your portfolio
• Share of packaging formats recyclable or reusable at scale
  

Modern dashboards pull all of this together in one view. A global panel shows total packaging tonnage and EPR fees; regional tabs flag upcoming deadlines (for example, Oregon’s first producer payments in 2026). Executives can instantly see where the company is ahead or at risk, and where design or supplier interventions could make the biggest impact.

In short: EPR data, when measured well, tells the story of both compliance and progress.

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The U.S. EPR Patchwork: A Quick Tour

The U.S. model differs from Europe’s single-market approach. Packaging EPR is state-driven. And those regulations, which are evolving “IRL”, are at different stages. Here’s a current snapshot:

• California (SB 54) - CAA approved as PRO; registration now open. First reports due Nov 15,2025, first fees due in 2026. 
• Colorado (HB 1355) - CAA designated as PRO; producer fees start 2026.
• Oregon (SB 582) - first approved program plan; rollout began in 2025.
• Maine, Minnesota, Maryland, Washington - laws passed, rulemaking underway through 2028.

For multinationals, the takeaway is clear: harmonize what you can, localize what you must.

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Implementation Roadmap: From Setup to Scale

Scaling EPR across multiple markets doesn’t happen overnight. It’s best approached in phases, starting with leadership and data foundations, then building toward automation and continuous improvement.

0–3 months: Appoint your executive sponsor and global EPR lead. Approve a standard packaging data model and audit the completeness of your master data  -  this becomes the backbone of all reporting.

3–6 months: Connect your product data (PLM/PIM) with sales and shipment data to map packaging to markets. Pilot your “rules engine” in one EU market and one U.S. state to test how fees are calculated and reported.

6–12 months: Launch your supplier portal so partners can submit recycled-content proofs and packaging declarations. Expand automation to additional markets, link EPR fee forecasts to your finance system, and close the loop by feeding cost and design insights back to packaging teams.

In summary: Build first for accuracy, then for efficiency. Once your data flows cleanly between design, suppliers, finance, and compliance and ESG, EPR becomes part of how your company runs better packaging - lower fees, reduced environmental impact - everywhere it sells.

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What Good Looks Like

When EPR is fully embedded, it stops feeling like an extra compliance burden and starts functioning as part of everyday business. Mature programs share a few hallmarks:

• Clear ownership. Every team knows its role -  packaging and data teams manage inputs, compliance leads filings, and finance tracks fees. A global EPR lead keeps it all connected.
  
• One data model. Packaging, sales, and supplier data live in a single structure, with GTINs tying every SKU to its materials, weights, and recycled content. That consistency makes reporting fast and credible.
  
• Integrated systems. Product data flows automatically to the markets where you sell, applying the right rules and fees for each jurisdiction. Reports can be generated and verified in days, not weeks.
  
• Active supplier partnerships. Vendors provide timely declarations and PCR proofs through clear SLAs, keeping compliance continuous rather than a last-minute scramble.
  
• Decision-ready dashboards. Leadership can see, at a glance, which markets are on track, where costs are rising, and how design changes could reduce future EPR compliance fees.‍
• Circular design feedback. EPR data is used to inform packaging choices- lightweighting, increasing recycled content, eliminating components,and replacing hard-to-recycle materials. Read our post on eco modulation to see how better design can reduce EPR fees.

That’s what “operating at scale” really means - not just staying compliant, but turning EPR into a managed, measurable part of how your business designs, sells, and reports packaging worldwide. If you’re looking for software and policy expertise to help manage EPR across multiple markets, PCX can help - learn more here.

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Stay Compliant Across Every Market

PCX’s software and regional experts make packaging EPR reporting simple. See how →‍

Explore our EPR essentials series:

• EPR 101: A Guide to Extended Producer Responsibility
• EPR Reporting Made Simple: The Core Data Every Producer Needs to Capture
• Design Smarter, Pay Less: How Eco-Modulation Makes EPR Work for Your Bottom Line
• EPR Regulations Worldwide: What Every Global Brand Needs to Know Now

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FAQ: Making EPR Work Across Markets

Q1. Who actually owns EPR inside a company?
Ultimately, compliance is shared, but accountability must be clear. The executive sponsor (often in sustainability or operations or compliance/legal) owns the targets and budget. Packaging and data teams own the inputs, while finance manages forecasting and payments. The key is a single global EPR lead who keeps everyone aligned. Without that, reporting turns into firefighting.

Q2. Do we need different EPR systems for each country?
No. The smartest companies use one global data model that feeds local reporting. You can think of it as one “packaging brain” with country-specific rule sets. That keeps consistency across brands and regions while allowing for local nuance, like California’s rules versus the EU’s PPWR.

Q3. How detailed does our packaging data really need to be?
Very. Many regulators now expect packaging hierarchy data (each, inner, case, pallet), weights, materials, and recycled content, all linked to your GTINs. If you can’t trace your data to that level, you’ll struggle to report accurately or defend your numbers during an audit.

Q4. What’s the biggest risk when scaling EPR?
Data quality. Incomplete or inconsistent data between packaging, suppliers, and sales systems causes most compliance errors. The second risk is underestimating supplier dependencies - if your vendors don’t deliver material or PCR proofs on time, your whole submission can slip.

Q5. How can EPR data actually drive business value?
When you track EPR fees alongside packaging specs, you see where design choices hit your bottom line. Lightweighting, switching materials, or increasing recycled content can all reduce fees and improve sustainability scores. In other words, EPR data is design intelligence, not just paperwork.