The May 31, 2026 Packaging EPR Report Deadline: Six-State Filing Checklist for Food Brands

For US-bound food brands and their importers, this is the week the new packaging EPR system stops being theoretical. By May 31, 2026 — or June 1 in California, where the calendar fell on a Sunday — producers covered by six state EPR laws have to file annual supply reports with the Circular Action Alliance (CAA). Miss it and you are visible: Oregon has already published a public list of noncompliant producers, and other states are watching.

Here is what the filing actually contains, which of your trading partners is responsible for submitting it, and the documents your packaging supplier should be sending you this week.

Six States, Two Report Types, One Deadline

CAA is the designated PRO for six of the seven states with active packaging EPR laws. The May 31, 2026 deadline applies to all six, but the reporting depth differs:

Full annual reports: California, Colorado, Oregon
Simplified reports: Maryland, Minnesota, Washington

California also requires a separate source reduction report by the same date, and uniquely asks for “the number of plastic components associated with covered material” — a granularity the other five states do not currently demand. CalRecycle has confirmed that because May 31 is a Sunday, California producers can submit both California reports by Monday, June 1, 2026 without penalty.

Every report covers 2025 supply data — the calendar year that just closed. If your team has not already pulled SKU-level sales by state for last year, that is the immediate task.

What the Filing Actually Asks For

The simplified report is built around eight material categories. For each one, producers report total weight supplied into that state in 2025:

Printing and writing paper
Metal
Rigid plastic
Wood / other organic materials
Glass / ceramics
Paper / fiber
Flexible plastic
Compostable materials

Full annual reports go further. As Ethan Redden of BSI summarized in industry guidance, full filings require both qualitative inputs (affiliated producers, brand estimation methodology, subsidiary list, validation approach) and quantitative inputs (2025 supply volumes, component-level packaging weights, breakdown by state-specific category, supporting evidence files). It is not a one-line submission. Producers that prepared early have been spending the spring reconciling sales-by-state data with packaging weight tables — a reconciliation that crosses sales, compliance, and finance.

The numbers matter because CAA uses them to set fees. As the advisory law firm Alston & Bird put it, “submitting accurate producer reports to CAA is a critical step in complying with EPR laws, as they are used as an input to accurately and fairly set EPR fees or dues that producers will pay to CAA.” Underreport and you risk audit; overreport and you fund the program more than you owe.

Who Counts as the “Producer” — Especially for Foreign Brands

This is the question most overseas food brands get wrong. EPR statutes typically rank candidates: the in-state manufacturer first, then the brand owner or licensor, then the importer or distributor. For a brand made in Asia and sold into California through a US importer, the responsibility almost always falls on the US importer — but the brand owner is one rung away and can be pulled in if the importer is inactive or absent.

Practically:

If you are a foreign food brand: confirm in writing this week which US entity is filing the CAA report on your behalf. Many importers have not done this filing before. Silence is a red flag.
If you are a US importer or co-packer: you almost certainly are the producer for the brands you bring in. Register with CAA if you have not, pull 2025 supply data from your customs entries and warehouse records, and confirm packaging weights with each supplier.
If you are a private label or marketplace seller: producer status depends on contract structure. A trade compliance review is cheaper than a missed-deadline appearance on a state list.

Why the Oregon List Changes the Risk Calculation

Oregon’s program has been the proving ground for what enforcement looks like. The state has notified noncompliant producers individually and published a public list of those who failed to register or report on time. That list is the kind of artifact that gets pulled into supplier-onboarding questionnaires, into retailer compliance reviews, and into journalists’ inboxes. Even if statutory penalties are modest in year one, brand exposure is not.

California’s separate filing structure and June 1 producer registration deadline under the now-final SB 54 rules adds parallel pressure for brands selling into that state. The two California obligations sit on top of each other this week — the supply report and the PRO registration — and they share underlying data.

The Documentation Your Supplier Should Already Be Sending

If you are a food brand or importer scrambling to compile the report, your packaging supplier should be able to hand you four items per SKU, ideally on a single spec sheet:

Component-level weight in grams for every part of the pack (container, lid, label, secondary packaging) — not a rounded gross weight
Resin or material identity with the appropriate code (PP, PET, PE, paperboard, bagasse, PLA, etc.), broken out by component
Recycled content percentage with supporting documentation, since this affects fee modulation in later program years
Recyclability or compostability evidence — BPI certificate for compostables, RecyClass or equivalent for recyclables, lab or specification sheet for fiber-based materials

If your current supplier cannot produce these, that is information about more than this week’s filing — it is information about your readiness for the 2027 fee year, when California’s fee mechanism turns on and the other state programs start fully invoicing.

What to Do in the Next Few Days

For brands and importers that have not yet filed:

Log into the CAA producer portal at circularactionalliance.org/producer-reporting and download the state-specific workbook for every state you sell into
Pull 2025 sales-by-state at SKU level from your ERP, including any direct-to-consumer shipments and marketplace channels
Request supplier spec sheets with the four data points above for every SKU on that list
Submit qualitative data first (entity structure, affiliated producers, brand estimation method) — these are the fields that hold filings up at the last minute
For California, plan to file both the annual supply report and the source reduction report together, by Monday June 1, 2026

The Bigger Picture

This first reporting cycle is the data foundation every future fee invoice will rest on. The brands that file accurate, well-documented reports this month will be the ones with defensible fee positions in 2027 and beyond. The brands that file rushed estimates — or that miss entirely — will spend the next year explaining themselves to CAA, to state regulators, and to retail customers who increasingly ask for EPR compliance attestations during vendor onboarding.

If you are a food brand selling into the US and your packaging supplier cannot produce component-level weights, resin breakdowns, and recyclability evidence on request, this filing cycle is the moment to upgrade the supplier. Talk to GQ TH Pack — we ship spec sheets that map directly to the CAA reporting categories and have already supported US importers filing in California, Colorado, and Oregon this month.