The evidence layer behind an EPR filing — OR / CO / CA

Your EPR report is filed. Can you reproduce the weights behind it?

PackClose traces reported packaging weights back to components, source documents, calculations, and state sales — so your team can identify evidence gaps before an invoice question, validation request, or Adjustment. CAA currently expects California early-fee invoices in August 2026, based on the CY2025 supply data producers reported — which makes “can we reproduce what we filed?” a this-quarter question, not a someday one.

The scan is a fixed-scope, invoiced engagement, paid upfront — no subscription and no card required · the in-browser tools and the demo run on synthetic data · nothing uploads.

How it works

  1. The status fork
  2. The data close
  3. Workpaper & substantiation

Schedule 01The status fork

Every engagement starts with the status fork

BRANCH · A

Submitted

Receipt on file? Methodology documented? We build the substantiation pack so a validation request is a same-week answer.

BRANCH · B

Late / unreported

We close the data gaps, prepare the portal-entry workpaper, and you (or your counsel) submit and record the CAA response. We never claim remediation cures noncompliance — we make the remediation defensible.

BRANCH · C

Invoice & validation ahead

California early-fee invoices expected August 2026 on CY2025 data, validation and Adjustment windows open on filed reports, next annual cycle — tracked with owners and evidence, not vibes.


Schedule 02Self-serve diagnostics

Find out where you stand — in about two minutes

The 2-minute EPR Status & Exposure Scanner

Pick your states, answer a few portfolio questions, and optionally paste a packaging BOM. You get a state-by-state status board, a gap list, and an illustrative exposure view. Nothing to install, nothing uploaded — it runs entirely in your browser.

RUNS IN-BROWSER · NOTHING UPLOADS Run the exposure scanner

Have your real BOM handy?

Drop the CSV on the file analyzer and see which data-close columns it carries, which components lack weights, and which materials need a category decision — the same deterministic mapping rules the platform runs, executed entirely in your browser. The file never leaves your computer.

RUNS IN-BROWSER · NOTHING UPLOADS Analyze a real file

Schedule 03The deliverable

The deliverable: a data close, not a dashboard

Component-level packaging BOM

Jar, pump, cap, label, carton, insert, DTC shipper; weights, materials, plastic detail, roles, and the source document for every number.

State sales allocation with lineage

Units × component weights to state/material kilograms; every cell traceable; estimates flagged, then replaced with actuals through a recorded correction.

California plastic detail

Plastic-only weight and plastic component counts, from day one.

QA-checked workpaper (XLSX) + substantiation pack

Methodology narrative, source inventory with hashes, supplier outreach evidence, correction chain — reviewed against our documented internal QA checklist by the engagement lead. Built to answer CAA validation requests.

Remediation queue

Missing data, supplier nonresponse, divergence questions — worked to zero, with every resolution attributed to a named owner.


Schedule 04Fit — we qualify hard

Is this for you? (we qualify hard)

Strong fit

Consumer brands/importers with obligations in 2+ of OR/CO/CA, roughly 50–2,000 packaging configurations, multiple suppliers/brands/entities, no component-level BOM, and material fee/audit exposure. Beauty and personal care especially.

Not a fit — we will say so on the first call

Exempt or clearly low-volume flat-fee producers, single-state simple portfolios, or companies already well served by an incumbent platform or consultant. A large purchase would be irrational — we’ll tell you that for free.


Schedule 05The correction regime

The real exposure is not the fee. It is the correction regime.

Most EPR pitches lead with fee savings. We do not quote or optimize fees, so we will make the argument that actually applies to you. Circular Action Alliance’s own reporting policy sets out what happens when a report gets pulled for validation — and every clause below is a reason your numbers need to be reproducible rather than merely submitted.

What CAA policy says
What that means for you
“Only one Adjustment request is permitted per Producer Report per Report Year. If multiple adjustments are needed, they must all be included in a single Adjustment request. Adjustment requests must be submitted within 24 months of the Report Date.” §3.12
Two separate lanes, two separate clocks. Producer-requested Adjustments are generally limited to one per Producer Report and Report Year — every change you need has to ride in that single, substantiated request. CAA-issued Corrections run on their own timelines (a 30-day response and a 60-day form — §3.11). A correction chain that shows what changed and why is what makes either lane answerable.
“If the Participant does not provide the requested documentation within 30 calendar days, the request will be closed and the Adjustment rejected” §3.12
Thirty days to produce source documents for numbers assembled up to two years earlier. This is precisely the deadline that a spreadsheet with no source trail cannot meet.
“CAA may require an independent third-party review at the Participant’s expense before approving the Adjustment” §3.12
An unsubstantiated position can convert directly into an audit bill you pay. Substantiation is not paperwork — it is the thing that keeps this clause from firing.
“If a Producer Report is identified for further follow-up or substantiation, CAA may, based on the findings, either proceed with invoicing or require a Correction as appropriate” §3.10
Validation reaches methods, categories, brands, and supporting evidence — and it is not a formality with a predictable end. Answering it in a week instead of a month is worth more than any fee optimization we could honestly promise you.
“Participants must retain all available decimal places in their data calculation until final submission”, with final figures rounded to two decimal places §3.6
Rounding policy is written into the regulation’s operating rules. We record the rounding rule on every portal total as part of its transformation lineage, because “that is how the spreadsheet did it” is not an answer.

Quoted from the CAA Reporting Policy, Version 2.0 (June 2026), published by Circular Action Alliance — retrieved 2026-08-15. CAA may validate reporting methods, categories, brands, and supporting evidence (§3.10); producer-requested Adjustments are generally limited to one per Producer Report and Report Year (§3.12), while CAA-issued Corrections follow separate 30-day response and 60-day form timelines (§3.11). Read the policy yourself; we would rather you did.


Schedule 06Where the lines are — by design

Producer status and exemptions are your calls — recorded with who decided and when, so each one holds up later. Portal filings stay with your authorized person; fee figures in our workpapers are labeled planning math, because CAAs invoice under approved rate schedules. And we choose depth over breadth on purpose: deep on OR/CO/CA, deadline-tracked on MN/MD/WA/ME.

And we will name the free thing you should look at first. The Sustainable Packaging Data Council publishes a free US EPR data-requirements template covering California, Colorado and Oregon — backed by Specright, Lorax EPI, Sonoco, Tyson and Costco. It is good, and it tells you which fields to fill. What it does not give you is a source document behind every weight, a transformation lineage on every total, a sealed version, or a correction chain. If the template alone gets you where you need to be, use it — we would rather tell you that than sell around it.

Schedule 07The console

The console

Every number below mirrors the live console’s synthetic demo workspace — every reported kilogram traces to a component, a weight, and a source document.

🔒 app.packclosehq.com
PackClose

Client area

My dashboard Guided setup Search Notifications 10 Export my data Verify integrity Trust Center
Signed in as Dana Operator
[email protected] · roles: operator

Golden Hour Beauty Co. (synthetic demo)

Packaging EPR Data Close & Substantiation · workspace opened 2026-07-24

EVIDENCE PIPELINE · 4 sources → 0 assertions → 2 sealed versions → 1 deliverable

Evidence coverage

90%

27 of 30 packaging components with a sourced weight

Aged open questions

0

open >30 days · 2 open total, oldest 30d · 0 blocking

Changed since sealed

0

approved values that differ from your last sealed snapshot

Regulator-response readiness

no drill run yet in this workspace

Run the drill — build the pack

Needs your attention

Nothing waiting on you. We’ll surface anything that needs a decision here.

Dates we track for you

Aug 2026California early-fee invoices expected (CY2025 supply data)CAA producer resource center
24 moAdjustment window on a filed Producer Report — one request per report per Report YearCAA Reporting Policy V2 §3.12

Render of the console in the new theme, using the live workspace’s synthetic demo numbers. The in-app theme matches — the data model, numbers, and behavior shown are the real product’s.

Schedule 08Pricing

Start with the readiness scan.

One fixed-scope, invoiced engagement first — so you know exactly what your evidence can and cannot support before anything bigger. Scope is priced by entities, states, configurations and supplier count, never by raw SKU count, because SKU count is not what makes this work hard.

The engagement to start with

$2,500fixed · invoiced · 5 business days

CAA Evidence Readiness Scan. One legal entity, one CY2025 product family, up to 20 packaging configurations or 75 components, up to two of California, Colorado, and Oregon. From your current report exports or submission receipts, one sales export, and up to five packaging/specification sources, we deliver: a component-to-source traceability sample, a reproduction of sampled state totals, a gap map of unsupported, estimated, and inconsistent data, methodology and calculation-lineage findings, Validation/Adjustment/Correction readiness actions, a QA-checked XLSX workpaper, and a 45-minute findings readout. Delivery within five business days after complete inputs. Full scope, deliverables, and exclusions →

After the scan — where the work goes next

Full data close

$8,500–$12,000

first entity-year · two states · invoiced

Component BOM build, allocation with lineage, reviewed workpaper plus substantiation pack, remediation queue worked to zero. The scan fee is credited against a close booked within 90 days, per your engagement letter.

Start the conversation →

CAA validation response

$3,500

fixed, per event · included for desk subscribers · invoiced

A report gets pulled and you have 30 days. Lineage, provenance, source inventory and the sealed version, assembled into one answer.

Start the conversation →

Annual & Change Desk

$1,000

per month · post-close, by proposal · 2–3 entities, up to 750 configurations, 3 states

The maintained position between reporting cycles — a post-close service, quoted by proposal after your Full Data Close: new packaging screened as it appears, supplier evidence requested through single-use links you send, deadlines tracked with owners. Group desk (4+ entities) quoted the same way. No self-serve checkout.

Ask after your close →

Single-entity, single-state portfolios are scoped down — ask. Annual prepay on the desk: two months free.

Every desk includes

  • Component and weight ledger with a source behind every number
  • Category mappings recorded as attributed human decisions — never invented, always sourced
  • Transformation lineage on every portal total: formula, inputs, units, rounding rule
  • Sealed tamper-evident versions with correction chains for post-submission changes
  • California plastic-only weight and plastic component counts, from day one
  • Unlimited supplier evidence requests — single-use response links, no supplier account, never metered. You send them; we record the ask and receive the answer.

How billing works, plainly: everything PackClose sells is invoiced under an engagement letter, after a fit check and an accepted agreement. The readiness scan is paid 100% upfront, due upon receipt, and work begins once payment has cleared. There is no self-serve checkout, no card at signup, no free-anything that converts into a charge, and no automatic subscription — anywhere. The sample data and the in-browser tools are open to explore without a sign-up, and they run on synthetic data. The Annual & Change Desk and Group Desk are post-close services, quoted by proposal after your Full Data Close. Your full data export never stops working, on every status. We do not file for you: exports are yours to submit.

Consultants and packaging engineers: this lane is deliberately partner-led. There is a referral share on attributed accounts and a wholesale tier if you would rather price it inside your own scope of work. Ask about the partner program.

Schedule 09Trust, plainly stated

Questions a data close must answer

Can numbers be edited after sign-off?

No. Completed workpaper versions are sealed (tamper-evident, hash-verified); corrections create linked versions with recorded reasons.

Who decides producer status / exemptions?

You, with your reviewer or counsel. We record the decision, its basis, and its date — we never compute it.

Where do the numbers come from?

Every kilogram traces to units × component weight with the source document; estimates are flagged until replaced.

Do you file for us?

No. You submit in the portal; we prepare the workpaper and record your receipt/status as evidence.

Is my data used to train AI models?

No customer data enters consumer AI tools. Model-assisted processing happens only under commercial no-training terms — or not at all, at your election.

Your security reviewer will want more than a table. The Security & Trust page lists every control by name with its actual status — shipped, armed at deploy, or not built — plus subprocessors, DPA availability, retention, and a direct answer on SOC 2. It includes a section on what we have not built, which is the part worth reading.

Read Security & Trust

Schedule 10Contact

Book a 20-minute fit check

Tell us your states, entities, and roughly how many packaging configurations are in play — and where your filed reports stand, if you know. We will tell you on that call whether the readiness scan fits, and say so plainly if it does not.

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