How to Estimate Packaging Weights for EPR Reporting

EPR fees are calculated by packaging weight, broken down by material type. If that sentence made you think “we don't track that,” you're not alone. Most brands don't have packaging weight sitting in a spreadsheet. Here's how to get from zero to a reportable number.

What EPR reporting actually asks for

Every EPR state requires producers to report the total weight of packaging they sell into that state, broken down by material category. The standard categories are:

• Recyclable plastic — PET, HDPE, PP containers and closures
• Non-recyclable plastic — PS, PVC, multi-layer pouches, film
• Corrugated cardboard — shipping boxes, corrugated trays
• Paperboard — cartons, folding boxes, labels
• Glass — bottles and jars
• Aluminum — cans, foil, closures
• Steel — cans, drums, strapping

You report in kilograms. Most states round to whole kilograms. The fee for each category is a per-kilogram rate that varies by state and recyclability — non-recyclable plastic costs 3–5x more than recyclable plastic in most fee schedules.

Method 1: Supplier packaging specifications

This is the most accurate method. If your packaging suppliers provide spec sheets, the weight per unit is usually listed. Multiply by units sold into each state.

This works for primary packaging (bottles, tubs, trays). It gets harder for secondary and tertiary packaging (shrink wrap, case packs, pallet wrap) because those specs aren't always broken out on the invoice. For those, see method 3.

Method 2: Weigh a sample

No spec sheets? Weigh it yourself. Get a kitchen scale or shipping scale that reads to 0.1g and weigh each component of one fully packaged product:

• Empty the product out (or zero-tare the scale with product, then subtract)
• Weigh each component separately: bottle, cap, label, film wrap, insert card, shipping box
• Sort each component into the correct material category
• Multiply by units sold into each state

For multi-SKU brands, group products by packaging type and weigh one representative SKU per group. A brand with 200 SKUs might only have 8–10 distinct packaging formats.

Method 3: Packaging spend as a proxy

If you can't weigh samples and don't have specs, use your packaging purchase orders. Total packaging spend divided by average cost-per-pound gives you total pounds. Then apply industry weight splits by material.

Average costs per pound (2025–2026, US market):

• Corrugated cardboard: ~$0.70–$1.00/lb
• PET plastic: ~$1.00–$1.50/lb
• HDPE plastic: ~$0.80–$1.20/lb
• Paperboard: ~$0.60–$0.90/lb
• Glass: ~$0.30–$0.50/lb (heavy, cheap)
• Aluminum: ~$2.00–$3.00/lb

You know your total packaging spend. Divide by the rate above for your dominant material, and you've got a defensible weight estimate. It's not audit-grade, but it's a legitimate starting point for your first report — and most PROs accept reasonable estimates during the early years of a program.

Allocating weight by state

EPR fees are owed per state — you don't report your total national weight, you report what you sold into each state. The standard approach:

1. Start with total packaging weight (from any method above)
2. Determine the percentage of your sales that went to each EPR state (by revenue or units)
3. Multiply total weight by that percentage

Use the same percentage for every material category. If 12% of your revenue is in California, 12% of your PET, 12% of your corrugated, and 12% of your film all go to California. The per-state split is the same across categories.

Most accounting systems can pull state-level revenue. If you sell DTC, your e-commerce platform probably has it. If you sell through distributors, ask them for sell-through data by state — or use population-based allocation as a reasonable approximation.

What counts as “covered material”

Not everything you ship is EPR-reportable. Here's what counts — and what doesn't:

California is the broadest — they include B2B and shipping packaging. Other states focus on consumer-facing packaging. Check each state's covered materials list before finalizing your report. See state-by-state guides →

Common mistakes

• Reporting product weight, not packaging weight. A 12oz beverage is ~340g of product. The packaging is the 22g bottle + 3g cap + 8g label. Only report the packaging.
• Forgetting tertiary packaging. Shipping boxes, stretch wrap, and pallet strapping count in California and most states. If you ship product, you have tertiary packaging weight to report.
• Using national totals instead of per-state allocation. Your PRO report for California is only the packaging that entered California. Use the allocation method above.
• Classifying everything as the worst category. This is the fastest way to overpay. PET bottles are recyclable plastic, not non-recyclable. Corrugated is one of the lowest-fee categories. Categorize correctly and save 15–30%. See eco-modulation strategies →
• Waiting for perfect data. Most PROs accept reasonable estimates in early reporting years. A good estimate filed on time beats perfect data filed late with penalties.

Quick reference: common packaging weights

If you're weighing samples, here are typical weights for common packaging items to sanity-check your numbers:

These are approximate ranges for sanity-checking your own measurements. Always weigh your own packaging when possible — actual weights vary by supplier and design.

The bottom line

You don't need perfect data to file your first EPR report. You need a defensible estimate based on the best data available. Start with supplier specs, fill gaps with sample weights, and use spend as a backstop. Allocate by state revenue percentage. Categorize materials correctly — it saves real money.

And if estimating weights across materials, states, and fee categories sounds like the kind of problem that should be automated — that's exactly what we're building. Estimate your fees now →