Why Understanding Your Supply Chain is Key to EPR Compliance 

As Extended Producer Responsibility (EPR) regulations continue to roll out across the U.S., producers in the petroleum and automotive sectors must take a proactive approach to ensure compliance. For many, especially those new to EPR, one critical step that is often overlooked is understanding how reporting responsibilities are shared (or not shared) across the supply chain. 

While EPR requirements may vary by state and material type, what remains consistent is this: producers must know exactly who is reporting what. Without clear agreements in place, there’s a real risk of gaps in reporting, double submissions, or even non-compliance. These are all issues that can result in costly penalties and regulatory headaches. 

That’s where Supply Chain Agreements come in. These agreements allow producers and their partners (distributors, importers, brand owners, retailers, and others) to clearly define roles and responsibilities around data collection and reporting for covered products and packaging. Establishing these Supply Chain Agreements helps reduce the likelihood of over- or under-reporting and ensures that compliance reviews go smoothly. 

To get started, producers should adopt the following best practices: 

• Define responsibilities clearly: Make sure each party in your supply chain understands and agrees on who is responsible for reporting what materials, in which jurisdictions, and under which timelines. 

• Engage with distributors and partners: Open a conversation with your distributors, retailers, or importers to identify where obligations lie for materials sold in EPR-regulated states. 

• Document everything: If a third party is handling your reporting, ensure you have written documentation that outlines their responsibilities. This is essential for compliance reviews and audits. 

• Review and update agreements regularly: EPR regulations are evolving quickly. Be sure to regularly review your supply chain arrangements to make sure they still align with current requirements. 

We’ve seen how a lack of clarity in supply chain reporting can lead to significant challenges for producers and we’re here to help our participants navigate these complexities and build strong, compliant systems from the ground up. 

Have Questions? Our Member Services team is here to help. Send an email to memberservices@interchange360.com and we’ll get back to you promptly. 

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If you’re still unclear about your reporting obligations, we’ve created this handy flowchart to help: