October 15, 2026

EPR Deadlines Are Coming: What Scrap and Recycling Operations Need to Report Before Year-End

EPR reporting for scrap and recycling operations comes due in two waves: filings and fee invoices that land before December 31, and January reports that depend on data you need to start assembling now. Oregon's Department of Environmental Quality (DEQ) expects life cycle reports from large producers by December 31. Pennsylvania manufacturers file their covered device reports by January 31, and recyclers sign them. Wisconsin e-waste recyclers file an annual report by February 1. Colorado and Oregon invoice 2027 producer fees in January.

Most of these filings belong to producers, not to your yard. Each producer report still rests on weights and dispositions that a recycler or processor has to supply and stand behind. This post covers which windows matter, where manual assembly breaks, and how lot-level tracking turns EPR reporting into an export instead of a project. It builds on our September post on ESG and traceability.

The EPR reporting windows that land before February

Five windows matter most for scrap and recycling operations between now and early 2027. The table shows who files each one, because that decides what your team is asked to provide.

CHART HERE

The packaging deadlines fall on producers. Recyclers and processors do not file them, but those producers and the organizations that serve them build their numbers from recovery and disposition records. Expect more data requests from customers in the weeks ahead. The e-waste deadlines work differently. In Pennsylvania, a recycler's signature sits on the filing, and in Wisconsin, the recycler files directly.

Program dates move, and the sources below are secondary summaries for the packaging items. Confirm each date with the state agency before you plan around it.

Sources (as of Oct 15, 2026): EPR Atlas reporting deadlines, Trayak 2026 state overview, Pennsylvania DEP stakeholder requirements, Wisconsin DNR recycler information.

EPR reporting windows from now through February 1, 2027

Most packaging filings fall on producers. The e-waste filings reach recyclers directly or through a signature.

EPR reporting windows, December 2026 to February 2027, with who files each one
Date State Program What is due Who files
December 31, 2026 Oregon Packaging EPR Life cycle evaluation reports to the Department of Environmental Quality (DEQ) from large producers on the top 25 lists Producers
Late 2026Date not published in the source Maine Packaging EPR Simplified supply report to set baseline obligations Producers
January 2027 Colorado, Oregon, California Packaging EPR First 50% installment of 2027 fees or dues, invoiced through Circular Action Alliance Producers
January 31, 2027 Pennsylvania Covered devices Annual manufacturer report with weight collected and recycled, signed by manufacturers and recyclers Manufacturers, with recycler certification
February 1, 2027 Wisconsin E-Cycle Annual recycler report with weight received for each manufacturer Recyclers

As of October 15, 2026. Confirm each date with the state agency before you plan around it. Sources: EPR Atlas, Trayak, Pennsylvania DEP, Wisconsin DNR.

How most yards assemble EPR reporting today

Most operations build EPR reporting at the end of the period. Someone exports scale tickets, someone else pulls settlements, and a third person matches both to customer names and material grades in a workbook. The workbook grows a tab for each program, and each program wants the same weights cut a different way: by manufacturer, by material, by quarter, or by disposition.

This works when volume is low and one person holds the logic in their head. It gets harder when a second yard joins, when a customer asks for a recovery number mid-year, or when the person who built the workbook takes a vacation in the week a report is due. The effort lands on operations and finance at the same time, in the busiest part of the calendar.

Where spreadsheet-based EPR compliance breaks

The first break is traceability. A weight on a report has to trace back to the tickets behind it, and a number that nobody can rebuild is a number an auditor will question. When a signature goes on a filing, as it does for Pennsylvania recyclers, the person signing is attesting to that chain.

The second break is what happens between the scale and the shipment. Material gets sorted, regraded, baled, or processed, and yield and shrinkage change the outbound weight. A report built from inbound tickets alone overstates what you recovered, while one built from outbound shipments alone misses what came in. Reconciling the two by hand is where discrepancies hide.

The third break is version control. Two copies of the workbook, one edited after the data pull, produce two answers to the same question. Finance books one number, sustainability reports another, and a customer receives a third.

The last break is time. Once a request arrives with a five-day turnaround, nobody has room to rebuild the lot history from scratch.

How lot-level data produces audit-ready diversion data

In September we covered why ESG reporting and traceability depend on the same records. EPR reporting makes that point concrete, because the filing date is fixed and the data has to be right the first time.

Loop ERP handles this at the source. Material Lot Tracking assigns a lot to material when it crosses the scale and carries that lot through sorting, processing, and shipment. Each lot keeps its weight history, its grade changes, and its final disposition. When yield or shrinkage shifts a weight, the change is recorded against the lot instead of absorbed into a spreadsheet adjustment.

Sustainability Reporting then rolls those lot records up by material, customer, and period. Because Loop ERP runs on NetSuite, the weights behind a diversion report come from the same records finance uses for inventory and settlements. A recovery number and a ledger number start from one source, so the two agree.

For the filings above, that changes the work in three ways. Your team can answer a customer's data request by running a report instead of rebuilding a workbook. An auditor can follow any reported weight back to the tickets and lot history behind it. And a program that wants the same weights cut by manufacturer, material, or quarter draws on one record set instead of a new tab.

For a deeper look at program requirements, see our EPR Compliance post. The lot and reporting features above are what make those requirements manageable day to day.

A year-end readiness checklist for EPR reporting

Start with the programs that touch your materials, then work backward from each filing date.

  • [ ]  List every program that names your yard, your customers, or your materials, and note who files each one.
  • [ ]  Confirm each date with the state agency or the producer responsibility organization.
  • [ ]  Pick 20 recent lots and trace each weight from scale ticket to shipment. Note every step that needs a manual fix.
  • [ ]  Agree with finance on one source for recovered weight, so reports and the ledger match.
  • [ ]  Set an internal data-ready date two weeks ahead of each external deadline.

FAQ

Does a scrap yard file packaging EPR reports?

Usually not. Packaging EPR filings fall on producers. Recyclers and processors supply the recovery and disposition data that producers and their organizations rely on, so expect requests from customers.

Which EPR reporting deadlines apply directly to recyclers?

It depends on the state and the material. Wisconsin e-waste recyclers file an annual report by February 1. In Pennsylvania, recyclers certify the manufacturer report due January 31. Check your own state program for other requirements.

What does audit-ready diversion data mean?

It means each reported weight can be traced to the tickets and lot history behind it, without rebuilding the numbers after the fact.

See it on your own data

See how Loop ERP connects yard operations, inventory, and finance in one system. Book a demo and bring a recent reporting request; we will walk through how lot records produce the numbers.

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