Packtally guide
Do I have to report packaging EPR? State thresholds explained
How to tell if your Shopify brand owes packaging EPR reports in Oregon, Colorado, California, Washington, Minnesota or Maryland, and which exemptions to claim.
Short answer: You likely have to report in a state if your brand is the producer of packaging sold into that state and you're above its small producer line, which is usually a revenue figure or about one ton of packaging into the state. Being under the line doesn't always end it: California's exemption has to be applied for and approved, and Oregon has a yearly window to claim its exemption.
The three questions to answer
- Are you the producer? For products sold under your brand, almost always yes. For the shipping box, it's whoever packs the order in most states, and the brand owner in California.
- Which states did your packaging go to? Use the ship-to state of every order you fulfilled in the data year.
- Are you over each state's line? Compare your revenue and the packaging weight you shipped into each state with the thresholds below.
Small producer thresholds by state
| State | Usually exempt if | Do you have to claim it? |
|---|---|---|
| Oregon | Global gross revenue under $5 million, or under 1 metric ton (about 2,205 lb) of packaging into Oregon | Yes. Oregon opens a yearly window for exemption claims; for the 2027 fee year it ran January 6 to March 31, 2026 |
| Colorado | Global revenue under $5,779,297 (the inflation-adjusted line), or under 1 ton into Colorado | Check the program's current rules each year |
| California | Under $1 million of gross sales in California in the most recent calendar year | Yes. Register in CalRecycle's reporting system and apply; the exemption counts only once approved, and must be kept up to date before it expires |
| Washington | Under $5 million, or under 1 ton into Washington | Simplified reporting for now |
| Minnesota | Under $2 million, or under 1 ton into Minnesota | Simplified reporting for now |
| Maryland | Under $2 million, or under 1 ton into Maryland | Simplified reporting for now |
Thresholds as we read them in October 2026, for orientation only and not legal advice. Revenue usually means all sales in all channels, including related companies, not just Shopify. Check each state's current rules before you rely on them.
How to estimate your tonnage in ten minutes
- Export a year of fulfilled orders from Shopify with the shipping state.
- Count orders by state.
- Multiply by a rough packaging weight per order. A typical online order ships with somewhere near a pound of packaging; weigh a few of your own packed orders minus the product for a better number.
- Compare each state's total with its line. 1 metric ton is about 2,205 lb.
If you're anywhere near a line, do the full calculation in How to calculate packaging by state before you decide.
What happens if you ignore it
The programs are active and penalties can be steep: California's law allows penalties of up to $50,000 a day per violation. Registering late can also mean reporting for earlier years you missed.
Sources
- Oregon DEQ: producers of covered products (exemption claim window)
- CalRecycle: small producer exemption
- Circular Action Alliance