Methodology & trust

How a kilogram earns its place in your report

This page explains the machinery behind the promises on the overview page: how every reported number gets its lineage, what we deliberately never do, how customer data is handled, and who reviews what. No hype - just the chain every value has to survive.

Provenance: field → source document → approver → immutable version → correction chain

Every value in the workpaper - a component weight, a units figure, a state/material kilogram - travels the same five-stage chain. A number that has not completed the chain is visibly an estimate or a gap; it cannot silently become part of the record.

1
Field. Each data point is a named field on a versioned workpaper - a jar weight, a state units figure, a plastic component count - never a loose spreadsheet cell. Every kilogram is computed as units × component weights, so each output cell has named inputs.
2
Source document. A field cannot be approved without a source document, and the link records the exact reference - document, page or cell, and timestamp. The source inventory carries document hashes; supplier outreach evidence is filed alongside. Divergent sources block approval until a human resolves them with a recorded rationale.
3
Approver. A named person approves each field and each completed version. Internal review and your data approval are separate recorded events - so "who checked this, and when" always has an answer. Estimates are flagged as estimates until replaced with actuals.
4
Immutable version. Once a workpaper version is signed off, it is immutable. The numbers behind the report you submitted stay exactly as approved. Export is not submission: you submit in the portal, and your receipt/status is recorded as an external event - the evidence that closes the loop.
5
Correction chain. When an estimate is replaced with an actual, a supplier corrects a weight, or an allocation input changes, a new linked version is created with a recorded reason. The old version is preserved and the audit trail is append-only - which is exactly what a CAA validation request wants to see.

Why immutability matters: a validation request asks how a number was built at the time you reported it. A workpaper that can quietly rewrite itself cannot answer that question - a correction chain can.

What we deliberately do not do

We do not log into or automate CAA/state portals, do not determine producer status or exemptions (those are recorded decisions by you and your reviewer/counsel), do not quote or optimize fees (fee figures in our workpapers are labeled illustrative planning math; CAA invoices under approved rate schedules), and do not cover all states - we go deep on OR/CO/CA and track MN/MD/WA/ME deadlines only.

This is the same boundary stated on the overview page, verbatim, because it does not change with the audience: producer status, exemptions, and submission are decisions and actions that belong to you, your reviewer, and your counsel. We record those decisions; we never make them.

How customer data is handled

No consumer-AI processing

No customer data enters consumer AI tools. If any model-assisted processing is used, it happens only under commercial no-training terms - or not at all, at your election, recorded in the engagement terms.

Controls before any real data

Before any customer document enters the workspace, a binding checklist applies: contracts (NDA/DPA), written customer data authorization, a named reviewer with recorded scope, an approved commercial no-training AI path (or none), an isolated workspace, MFA, least-privilege access, encryption, access and audit records, malware scanning on upload, and backup/recovery.

Retention with a purpose

The reviewed workpaper, substantiation pack, source inventory (with hashes), and full version history are retained for the engagement's agreed retention period so a CAA validation request is a same-week answer - and everything is exportable to you on demand.

Deletion, honestly stated

At the end of an engagement, data is exported to you and deleted on request under the agreed retention/deletion procedure. One honest caveat: an active retention obligation or legal hold blocks deletion until it lapses - and that block is itself recorded, not silent.

The review model: qualified people, recorded decisions

Software surfaces problems; it never decides them. Every material decision passes through a person whose qualification and reasoning are on the record.

ElementHow it works
Qualified reviewerMaterial approvals reference an active qualification covering the module - "someone looked at it" is never anonymous or unqualified.
Recorded decisionsWho decided, what they decided, the basis, and the date - captured for every resolution, approval, and correction, in an append-only audit log.
Separation of eventsInternal review and your data approval are separate recorded events on every workpaper version - two signatures, two timestamps, never merged.
Blocking checksA field with no source document, or with unresolved divergence between sources, cannot be approved. The remediation queue is worked to zero with a named reviewer; nothing is waved through.
Your decisions stay yoursProducer status, exemptions, and what to submit are decisions you make with your reviewer or counsel. We record the decision, its basis, and its date - we never compute it.

Frequently asked questions

Which deadlines does this work revolve around?

Oregon, Colorado, and California annual supply reports (CY2025 data) were due May 31, 2026 - now past - as was California's baseline producer report (CY2023 data). California's individual source-reduction plan is due August 1, 2026, with early fees invoiced around August 2026; MN/MD/WA interim reports were also due May 31, 2026. Fee obligations began July 1, 2025 in Oregon and January 2026 in Colorado; California fees start January 2027. Dates per the Circular Action Alliance producer resource center (circularactionalliance.org) - regulatory state drifts, so verify against the official source before relying on any date here.

Do you submit our reports in the portal?

No. You submit in the portal; we prepare the portal-entry workpaper and record your receipt/status as evidence. We never claim remediation cures noncompliance - we make the remediation defensible.

Who decides producer status and exemptions?

You, with your reviewer or counsel. We record the decision, its basis, and its date - we never compute it. The same goes for any question that determines whether and what you must report.

Do you calculate or optimize our fees?

No. Any fee figures in our workpapers are labeled illustrative planning math. Invoicing happens through CAA under approved rate schedules - we do not quote, compute, or optimize fees.

Which states do you cover?

We go deep on Oregon, Colorado, and California, and track MN/MD/WA/ME deadlines only. If your obligations sit mostly outside that footprint, we will say so on the first call - a large purchase would be irrational, and we'll tell you that for free.

Can numbers change after sign-off?

Not silently. Completed workpaper versions are immutable; corrections create linked versions with recorded reasons. Estimates are flagged as estimates, then replaced with actuals through a recorded correction - so every kilogram stays traceable to units × component weight and its source document.

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.

What does the free exposure scanner do with what I enter?

Nothing leaves your browser. The 2-minute EPR Status & Exposure Scanner runs entirely client-side - nothing is uploaded, nothing to install, and closing the tab discards everything, including any packaging BOM you paste.

Exposure views and any fee-adjacent figures are illustrative planning math, never a quote. Verify every date and obligation against the official state and CAA sources before relying on it.