Analyst Insight: Extended producer responsibility (EPR) laws in the U.S. are increasing demand for product-level transparency. Compliance depends on two core data capabilities: Consistent product identification across packaging hierarchies and legal entities, and structured packaging attribute data that can be reused across state jurisdictions.

Evolving environmental policies are introducing substantial reporting obligations across global supply chains. In the U.S., EPR packaging laws have now been enacted in seven states: Maine, Oregon, Colorado, California, Minnesota, Maryland and Washington, with more expected to follow. 

While each state operates its own program with distinct timelines, material classifications and fee structures, they share a common model: Producers must register with a producer responsibility organization (PRO), report the packaging and materials they introduce into the market, and pay fees based on material volume and recyclability. PROs use those fees to fund collection, sorting and recycling infrastructure, shifting end-of-life responsibility away from municipalities and taxpayers and toward the companies that put packaging on the market.

Meeting these requirements depends on reliable, interoperable product data. Yet packaging composition, product identifiers and supply chain events are often managed in disconnected systems, making regulatory reporting difficult and time-consuming.

Improving traceability and data interoperability can help companies navigate this complexity. Two core data capabilities are becoming essential for the next generation of environmental reporting:

Standardized identification across products, packaging and locations. Consistent identification of products and their movement through the supply chain is foundational to regulatory reporting. Companies often sell the same product in multiple markets, packaging formats or configurations, each with different environmental attributes.

Unique product identifiers such as GS1 Global Trade Item Numbers (GTINs) enable organizations to identify trade items and packaging configurations consistently across systems and trading partners. When used consistently in manufacturing, distribution and retail systems, GTINs allow companies to associate packaging materials, weights and recyclability attributes with specific items.

Equally important is identifying the legal entities responsible for placing products on the market. Global Location Numbers (GLNs) provide a standardized way to identify legal entities, functional entities, and physical locations across the supply chain. For EPR specifically, GLNs support the determination of which party holds producer status in a given jurisdiction, which is a prerequisite for registration and fee assignment under every enacted state program.

Together, standardized product and location identification create a shared reference framework, helping organizations align data across partners and jurisdictions and determine responsibility for placing products on the market.

Structured product and packaging data to support transparency. Many organizations already have the data needed for EPR reporting, but it often resides in packaging files, supplier documents or excel spreadsheets that aren’t easily integrated into compliance workflows. Capturing packaging attributes as structured product data, tied to each item record and organized by component, allows that information to be used consistently across reporting periods and state jurisdictions.

Core data elements required across current EPR programs include:

• Material type and classification, aligned to each state’s standardized category list (e.g., PET bottle, aluminum container, corrugated cardboard);

• Weight per unit, at the packaging component level;

• Recycled and post-consumer recycled (PCR) content;

• Recyclability, assessed against state-specific standardized material lists;

• Volume of covered materials introduced into each state;

• Packaging format and component structure (primary, secondary, tertiary), and

• Eco-modulation attributes that affect fee rates, such as recyclability performance and recycled content percentage

Eco-modulation is a particularly important concept. Most enacted state programs structure fees to reward readily recyclable packaging and impose higher rates on hard-to-recycle formats. And accurate, granular packaging data isn’t just an administrative requirement because it directly affects what producers pay.

EPR programs require brands to submit this data to PROs, which use it to calculate fees and track progress against recycling targets. Because each state maintains its own material classification categories and reporting structures, the same underlying product data must be mappable to different jurisdictional requirements. Managing packaging attributes as part of structured product master data at the GTIN level enables that reuse without re-collecting data for each program.

EPR laws reflect a broader shift in how companies are expected to account for the environmental impact of the products they sell. Transparency around materials, product composition and supply chain activity is becoming essential for doing business.

Organizations that strengthen product identification, data standardization and traceability capabilities today will be better positioned to respond as regulations evolve. Beyond supporting regulatory fulfillment, improved supply chain data can also help organizations better understand environmental impacts and identify opportunities to improve product design and material use. 

As environmental reporting expectations expand, reliable product data will play an increasingly central role in regulatory readiness and supply chain transparency. Digital tools that support transparency can help companies address current requirements while preparing for how those expectations may change.