Why component-level, not SKU-level
To be precise about what is required versus what is wise: state filings generally ask for material-category totals, not a component-level bill of materials — and California separately uses plastic-only weight and plastic-component counts for source-reduction reporting. Its guidance treats items such as coatings, adhesives, inks, liners, labels, caps, and windows as potential components. Component-level records are the internal substantiation and calculation layer we use to produce those totals, because 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 substantiate that math when someone asks how it was built. The unit of account that survives questions is the component: the carton, the insert, the film, the label, each with its own material, weight, and count per sellable unit.
Sources rechecked 2026-09-04: CAA Producer Resource Center; CalRecycle Source Reduction Reporting Guidance.
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 an attributed human decision with a citation, not a guess. California’s plastic component information includes plastic-only weight and component counts.
- 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 may be the producer under the applicable state definition, and associated producers must keep it unambiguous which entity reports which data. Both are attribution problems — much easier to review in a source-linked data model than across disconnected spreadsheets.
State guidance documents and FAQ: CAA Producer Resource Center (rechecked 2026-09-04).
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 attributed human decisions. We flag differences between state category lists instead of flattening them and record who resolved each mapping.
See where you stand in the 2026 status guide, or run the Status & Exposure Scanner in your browser.