Minnesota packaging EPR reporting entered a distinct early stage that trips up many multi-state producers: the pre-program phase. In this phase, Minnesota, Maryland, and Washington accept a “simplified supply report” built on aggregated material weights rather than the SKU-level and component-level detail required by California, Colorado, and Oregon. Understanding that difference is the single most useful thing a compliance team can do before the next cycle.

This explainer focuses on the reporting mechanic itself: what pre-program reporting is, what the simplified report contains, how it differs from full reporting, and how to assemble the data once so it survives the transition to detailed reporting later. For the broader state-by-state obligations, registration steps, and enforcement detail, use Certivo’s fuller Minnesota, Maryland & Washington packaging EPR compliance guide alongside this piece.

If you are unsure whether your packaging triggers obligations in any of these states, Request a Compliance Review to confirm applicability before you build reports.

Key Takeaways

📌 Minnesota, Maryland, and Washington are in the “pre-program” phase and accept a simplified supply report instead of full SKU-level reporting.

📊 The simplified report uses aggregated 2025 material weights grouped into a small set of broad categories, not per-SKU or per-component detail.

🔗 Circular Action Alliance (CAA) is the producer responsibility organization operating these programs, and registration is the gateway to the reporting portal.

⏳ The first simplified report covered 2025 data and was due May 31, 2026 (a CAA-set date, not a statutory one); that cycle has passed, so late filers should register and report.

⚠️ Detailed material categories for these three states are not yet finalized, and detailed reporting will not occur until after each program plan is approved.

🏭 Minnesota interim reports were limited to packaging supplied for personal, noncommercial use, to align with Maryland and Washington.

🤖 Capturing packaging data once and mapping it to each state removes most duplicate effort when reporting shifts from simplified to detailed.

What “Pre-Program” Packaging EPR Reporting Means

Extended producer responsibility (EPR) shifts the cost of managing packaging waste to the companies that place packaging on the market. Seven US states have enacted comprehensive packaging and paper EPR laws: California, Colorado, Maine, Maryland, Minnesota, Oregon, and Washington.

Those states are not at the same maturity. California, Colorado, and Oregon are further along and already require detailed producer data. Minnesota, Maryland, and Washington are in an earlier stage that CAA labels “pre-program.” The 2026 filing for these three states is formally called the “Interim Producer Report: Simplified Reporting Categories,” covering the 2025 data year.

The practical meaning is simple. The detailed reporting infrastructure does not exist yet in these states, so CAA collects a lighter data set now to support program planning. For context on the regulation itself, see Certivo’s extended producer responsibility framework page and its consumer goods industry overview.

Simplified Supply Report vs SKU-Level Reporting

This is the distinction that matters most for data collection and should drive how you staff the work.

California, Colorado, and Oregon require annual supply reports with SKU-level and component-level data, including material composition, recyclability classification, and volume for each packaging component. Minnesota, Maryland, and Washington require a simplified supply report based on aggregated material weights. The simplified approach lets producers roll up existing detailed data into broader buckets rather than reporting each component. EPR Deadlines Are Arriving: What to Do Before May 31 +2

Simplified versus SKU-level packaging EPR reporting comparison for Minnesota producers

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What the Simplified Supply Report Contains

The simplified report asks for 2025 supply weights grouped into a small number of broad material classes. Based on CAA guidance, these simplified categories include printing and writing paper, metal, rigid plastic, wood and other organic materials, glass and ceramics, paper and fiber, flexible plastic, and compostable materials, with producers aggregating weights from their existing detailed categories into the appropriate simplified bucket. alston

Because CAA guidance evolves, confirm the current category set and any state-specific workbook inside the CAA producer portal before each filing. Report only covered materials, and exclude non-covered packaging from reported weights.

The Minnesota “Personal, Noncommercial Use” Nuance

Minnesota’s statute defines packaging more broadly than Maryland or Washington, which creates a scoping trap. For the interim report, CAA guidance limited Minnesota reporting to packaging supplied for personal, noncommercial use, to ease administrative burden and align the three states. Teams that applied Minnesota’s full statutory definition to the interim report likely over-reported. This is exactly the kind of state-specific rule that benefits from standardized, repeatable data collection. hlc

Who Counts as an Obligated Producer

A producer is generally the brand owner, manufacturer, or importer that first introduces covered packaging into a state. Out-of-state brands, importers, and e-commerce sellers are frequently in scope even without a physical presence. The producer definitions and exemptions differ by state, so status must be confirmed per jurisdiction rather than assumed from one state’s rule.

Low-Volume and De Minimis Considerations

Each state provides some relief for small producers, and the thresholds are not uniform. Washington, for example, offers exemptions for certain very small producers, and affiliate weights are counted when testing low-volume eligibility. Based on currently available regulatory guidance, confirm the exact revenue and tonnage thresholds against each state’s current rules and CAA guidance before claiming an exemption. The fuller compliance guide covers producer hierarchies in more depth, and Certivo’s support for compliance and regulatory managers is built to make this determination defensible across thousands of SKUs.

Pre-Program Deadlines and Registration Status

All three states route registration and reporting through CAA, and only registered producers reach the reporting portal and state workbooks. The first simplified report has already passed, so the near-term task is to confirm registration, close any late filing, and prepare for the next cycle.

Enforcement sits with the state agencies, not CAA: the Minnesota Pollution Control Agency, the Maryland Department of the Environment, and the Washington Department of Ecology. Confirm penalty specifics with the relevant agency rather than relying on secondary summaries. Managing these dates as recurring events, not one-time tasks, is where teams replace spreadsheets with a scalable system.

Minnesota packaging EPR pre-program reporting timeline across MN, MD and WA

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From Simplified to Full Reporting: What Comes Next

Simplified reporting is temporary. In Maryland, Minnesota, and Washington the detailed material categories are not yet finalized, and detailed producer reporting will not begin until after each state’s program plan is approved. When that happens, these states move toward the component-level detail California, Colorado, and Oregon already require.

Two points shape how you should plan. First, these three states are not expected to assess fees until at least 2028, while the detailed first-mover reports already feed fee setting beginning in 2027. Second, CAA uses the interim reports for program planning across all three states and, in Washington only, to inform early fee setting. So the “simple” Washington report still carries financial weight. EPR Deadlines Are Arriving: What to Do Before May 31 +2

The strategic implication is that the data you build now should be structured for the detailed future, not just the simplified present. Teams preparing for the EU Packaging and Packaging Waste Regulation and digital product passports can reuse much of the same packaging and material data for these US programs.

How to Prepare Pre-Program Packaging Data Efficiently

The form is rarely the hard part. The difficulty is assembling accurate 2025 packaging weights from procurement records, packaging engineering specifications, and co-packers, then mapping that data to each state’s covered-material definitions and simplified categories.

A durable approach captures packaging composition once at the SKU or component level, then aggregates up to whatever categories a given state requires. That single structure answers the simplified report today and the detailed report later without rebuilding. This is the core argument for a centralized materials and environmental compliance backbone and for audit-ready documentation that time-stamps what was reported and when.

Struggling to consolidate packaging data from suppliers and co-packers before the next cycle? Book a Demo to see how Certivo organizes it once and maps it to every state.

Certivo functions as the system of record for this data. CORA, its regulatory intelligence layer, tracks how each state program evolves and flags changes that affect your SKUs, supporting the horizon-scanning these emerging laws demand. Automated supplier data collection and AI-assisted document parsing reduce the manual effort of gathering and validating packaging data, while BOM and packaging-level material mapping lets one data set serve Minnesota, Maryland, Washington, and EU frameworks. For adjacent reporting, see how Certivo streamlines ESG data collection across the supply chain.

Executive Takeaway

Pre-program reporting is a planning window, not a pause. The simplified supply report asks for less, but the data feeds program design and, in Washington, early fees. Minnesota packaging EPR obligations will tighten toward detailed, SKU-level reporting once program plans are approved, and the producers who structured their packaging data early will file from an existing system instead of rebuilding under deadline pressure.

The most efficient path is to treat packaging data as a single, reusable asset across states and frameworks. To pressure-test your exposure across MN, MD, WA, and EU programs, Speak with a Compliance Specialist.