Oregon reports penalties up to $25,000 a day for unregistered producers
Packaging EPR laws are on the books in seven states, and your reporting obligations run on data your team keeps in spreadsheets and supplier emails. Oregon and Washington requirements are already in effect, and California fee implementation begins January 1, 2027. EPR rarely has one clear owner, which is exactly why the gaps stay invisible until a state asks.
What the 20 questions actually cover
Twenty questions across four areas, each scored two, one, or zero, out of 40 possible. If you can't answer a question today, score it zero. The questions you can't answer are the ones that cost you later.
- Data availability: whether your packaging inventory holds up by SKU and by material type.
- Supplier coverage: whether every co-manufacturer and contract packer in your EPR scope is identified.
- System readiness: whether you can answer an unannounced state inquiry the same business day.
- Team accountability: whether anyone at your company actually owns EPR registration and reporting.
- Corrective action: who escalates and who investigates when an EPR gap turns up.
- Your risk band: where your score lands and what to fix first at that level.
Most of this already lives in your food safety records
Supplier documentation, lot-level traceability, and change management when a spec moves: your food safety program already runs all of it. The gap is usually packaging component weight by material type, which nobody captured because nobody had to report it. That's the work this scorecard finds.
Run this at every site, then compare
Your company-level compliance is only as strong as your lowest-scoring site, so score each facility separately. The 2,500+ facilities on SafetyChain already keep these records centralized for food safety.
