12.17.2025
2026 Packaging and Paper Products Reports: Why the May 31 Deadline Requires Action Now in Canada and the United States
May 31: a recurring deadline… with the same challenges
In both Canada and the United States, May 31 has become a well-known milestone for producers subject to Extended Producer Responsibility (EPR) programs applicable to Packaging and Paper Products (PPP). This is the deadline by which annual reports must be submitted to the various stewardship organizations and Producer Responsibility Organizations (PROs).
Despite its predictability, this deadline continues to represent a major challenge for many organizations. Not because submitting the report itself is particularly complex, but because the upstream work – data collection, validation, and structuring – is often underestimated.
May may seem far away. In reality, for a compliant and reliable report, preparation must begin several months in advance.
EPR reporting: far more than an administrative exercise
At first glance, PPP reporting appears simple: reporting quantities placed on the market. In practice, it is a cross-functional exercise that requires:
- Sales data (by product, by jurisdiction).
- Information on primary, secondary, and tertiary. packaging.
- Clear distinction between B2C and B2B sales.
- Precise material classification.
- Rules specific to each province, state, or agency.
Each step involves grey areas, regulatory interpretation, and a risk of error.
Why starting now matters – even if May feels far away
Several factors explain why waiting until spring to begin preparation is risky.
1. Data is not centralized
The information required for EPR reporting rarely comes from a single system. It is often spread across:
- Sales systems or ERPs.
- Finance, compliance, or product development teams.
- Packaging suppliers.
- Logistics data
Bringing it all together takes time – and multiple iterations.
2. Packaging evolves faster than expected
Supplier changes, format modifications, lightweighting initiatives, and new materials mean packaging is not static. Without structured tracking, reported data can quickly become outdated or inaccurate.
3. The rules change
Every year brings regulatory updates in both Canada and the United States. Waiting until the last minute increases the risk of reporting under outdated requirements.
Non-compliance: very real consequences
Non-compliance is no longer theoretical. It increasingly results in:
- Financial penalties.
- Retroactive charges and interest.
- Targeted audits.
- Increased regulatory exposure.
Reporting as a risk management tool
More and more, EPR reporting is viewed not only as a regulatory obligation, but as a risk management tool:
- Financial risk (overpayment or underreporting of EPR fees).
- Regulatory risk (audits, penalties).
- Operational risk (last-minute mobilization of internal teams).
- Reputational risk.
A structured, well-documented, and forward-looking approach significantly reduces these risks.
Canada and the United States: constantly evolving regulatory frameworks
While EPR programs share common principles, their implementation varies significantly by jurisdiction.
In Canada
Producers must navigate:
- Different rules by province.
- Key distinctions between the residential and industrial, commercial, and institutional (IC&I) sectors.
- Specific requirements for printed materials and service packaging.
- Ongoing adjustments to material categories and fee schedules.
Business-to-business (B2B) sales, often excluded or partially exempt, become a major challenge when poorly documented.
In the United States: growing complexity
Packaging EPR programs are expanding, but they are not harmonized. Each state adopts its own model, definitions, and requirements.
California: a case of its own
California is often regarded as one of the most complex frameworks due to:
- Broad definitions of packaging and printed materials.
- High expectations for data traceability.
- Direct links between reporting, environmental performance, and financial obligations.
- Increased expectations placed on producers, even well ahead of formal deadlines.
Understanding what must be reported, how, and when requires a careful review of legislation and regulatory guidance.
The Oregon example
Oregon is frequently cited for the strictness of its enforcement framework. Penalties for non-compliance can be substantial: up to $25,000 per day, in addition to retroactive corrective obligations.
In this context, an approximate or late report can cost far more than the effort required to prepare properly in advance.
Conclusion: May 31 starts now
Every year, the same conclusion emerges: organizations that begin their preparation early benefit from:
- More reliable data.
- Better-informed decision-making.
- Less operational stress.
- A stronger ability to respond to questions from stewardship organizations and regulators.
Even if May still feels far away, the 2026 reporting cycle is already underway. Starting now means putting yourself in a position to submit a compliant, defensible report that reflects current regulatory realities, both in Canada and in the United States.