Guide · published 2026-07-17

Component-level packaging data: what a defensible supply report is built from

Fee schedules price materials, not SKUs. The unit of account is the packaging component - with a source document behind every number.

Why component-level, not SKU-level

EPR fees are built on material data. CAA's published fee methodology has base fees varying by packaging type and eco-modulated adjustments on top — incentives and disincentives tied to material choices. A SKU-level total (“the box weighs 300 g”) cannot support that math. The unit of account is the component: the carton, the insert, the film, the label, each with its own material, weight, and count per sellable unit.

Fee structure: CAA Producer Resource Center, producer FAQ (checked 2026-07-17).

The record that survives questions

A defensible supply report decomposes into records shaped like this:

  • Configuration — the sellable unit as shipped (SKU + packaging configuration, not just the product).
  • Component — every physical packaging piece in that configuration, with its function and packaging level.
  • Material and submaterial — classified against the state's own guidance, not a generic list. CAA publishes state-specific “Covered Materials and Producer Definitions” documents (Oregon 2026 updates; Colorado 2026; California May 2026 v12; Washington; Maryland; a Minnesota producer-definition document) — category mapping is a reviewed decision with a citation, not a guess.
  • Weight per component (grams) and count per unit — with the source document attached: a component spec, a certified scale record, a supplier declaration.
  • Sales attribution — units by state, year, and channel, because obligation and fees follow where covered material was supplied.

Two organizational facts from CAA's FAQ are worth engineering for early: retailers with private-label covered products are themselves obligated producers, and associated producers (common-ownership scenarios) must keep it unambiguous which entity reports which data. Both are attribution problems — solvable in the data model, painful in a spreadsheet.

State guidance documents and FAQ: CAA Producer Resource Center (checked 2026-07-17).

Data-quality practices we hold ourselves to

  • Provenance on every field. Each weight, count, and category answers “which document says so?”
  • No silent unit conversions. A value in kilograms against a grams field is an exception to resolve, never an automatic ×1000.
  • Corrections as a chain, not an overwrite. When a number changes after a report is complete, the prior version stays, and the correction carries its reason.
  • Category mappings are reviewer-approved. We flag divergences between state category lists instead of flattening them.

See where you stand in the 2026 status guide, or run the Status & Exposure Scanner in your browser.

Honesty note. PackClose is independent of CAA and every state program; nothing here is legal advice. Category examples on this page are illustrative — customer-facing mappings are built from the state guidance documents current at engagement time.