I Spent June 1 in Spreadsheet Purgatory — Here's What the EPR Deadline Actually Teaches Us

Breathe. Then get moving. Compliance experts and a packaging coordinator who lived through May 31 share what's next.

At 9 AM on Tuesday, my direct message line lit up. "Congrats — we made the deadline." My colleague. I stared at my own inbox — still 23 unread threads from the prior evening — and realized the May 31 EPR deadline had come and gone. The thing nobody says about passing a massive compliance deadline is that the next morning, you're still the same person staring at the same spreadsheets. The work doesn't stop.

I'm a packaging coordinator at a midsize CPG company — about 200 people. I've been handling our packaging compliance for about four years now, which means I was in the thick of it when the harmonized deadline for reporting baseline data under the new state EPR programs hit. And I won't lie: the lead-up was messy. But now that we've cleared it, I've been debriefing with my network, reading the expert takes, and mostly, figuring out what now actually means. Here's my read — backed up by folks from Eunomia, Pure Strategies, EY, and Washburn Consulting.

The Deadline Passed. But That's Just the Opening Act.

The common deadline from Circular Action Alliance (CAA) on May 31 was a big deal — it meant six states (California, Colorado, Maine, Maryland, Minnesota, Oregon, Washington) all wanted data on the same date. Washburn Consulting's Michael Washburn put it well: "The reports were due on the same day, but the reports themselves differed." Each state has its own nuance. Some want material broken down by component. Others define "packaging" differently. One size doesn't fit all, even with a harmonized date.

And here's the part that hit home for me: Pure Strategies' Cheryl Baldwin mentioned that "overwhelmed and confused" were the main emotions. That tracks. In the weeks before the deadline, I was on calls with peers at smaller companies who were learning about this for the first time — literally weeks before the deadline. If you were one of those people, you're not alone. And the good news? You're not as late as you think.

What the Numbers Actually Tell Us

Let's look at the raw numbers. In California, CAA reported that 2,719 producers had registered as of March 2026. But upward of 3,300 were missing. Washburn estimated that in early April, "half or fewer of the total producers in any state were engaged and registered." He broke it down: 50% are simply unaware, 10% are waiting for final rules, 15% are actively choosing not to participate, and 25% are trying to figure out what to do.

If you're in that 50% who didn't know — or that 25% who are stuck — here's the message from every expert I've read: Don't panic. But do start moving.

"Your mission is not to generate a report, your mission is to stand up a compliance program." — Michael Washburn, Washburn Consulting

I learned this the hard way in my own first year. I thought the goal was to produce a clean spreadsheet. I was wrong. The goal is to build a system that can produce that spreadsheet every year, with better data each time. The report is the output, but the process is the product.

First, Get Visible. Then Get Smart.

The most actionable takeaway from Washburn: "You're late but it's still early. There's a certain level of grace." The highest risk is doing nothing. So first step: register. Make yourself visible. Even if your data isn't perfect, being in the system dials down your risk significantly. Oregon has already started sending delinquency notices and publishing noncompliant lists — and that's actually doing the industry a favor. As Anna Kendall from EY said, "That framing is important for companies." It shows the law has teeth, which means the free-rider problem will shrink over time.

Don't Build Your Data Quagmire — Build Your Team First

Here's the mistake I almost made: I started building spreadsheets before doing the governance work. Washburn nailed it when he said: "Get your brain out of the data quagmire and focus on governance, because this is a forever problem." You need people who can make decisions about source reduction, material usage, and long-term goals — not just someone who can copy numbers into a cell.

Baldwin emphasized this is not a one-person job. You need legal, finance, operations. And you need to have the conversations with suppliers now — not when the next deadline is six weeks away.

Three Phases Before You Get to Innovation

Baldwin described a path that rang true for my own experience. First phase is the initial lift — figuring out who to involve and how to pull the data. Second phase is the adjustment — refining the data collection and reporting. Third phase is maintenance — where the process becomes routine.

And then — if you do it right — comes the fourth phase: fee optimization. Ecomodulation will kick in soon. Wasserman from Eunomia pointed out that "ecomodulation of fees will kick in soon," and now that companies have some experience reporting, they should start thinking about redesign and material choices that actually reduce fees. That's where compliance turns into competitive advantage.

That's the part I'm excited about. But you can't get there unless you get through phases one through three first.

What I'd Tell Anyone Still Staring at the Dashboard

If you missed the May 31 deadline or are still figuring out your approach:

• Don't sit in paralysis. Register with CAA. Get visible.
• Call a peer. Washburn suggested talking to another company in your space. I found that our trade association actually had a working group that saved me weeks of research.
• Hire help if you need it. Compliance consultants exist for exactly this reason. The cost of getting it wrong — fines, legal exposure, reputational damage — dwarfs the consulting fee.
• Build for repeatability. The first year is the worst. My second go-round was already 60% faster because I had a process, not just a file.

"The work doesn't stop May 31." — Michael Wasserman, Eunomia

If I could go back and tell my pre-deadline self one thing, it's this: you're not building a report. You're building a compliance muscle. And the sooner you start, the sooner you can stop thinking about the deadline and start thinking about the opportunity — which is exactly where the smart companies are heading.

Now, if you'll excuse me, I have to update my 2027 compliance calendar. But at least this year, I know what I'm doing.