A 10-day pre-submission audit cut one brand's EPR fees by 24% before filing.

The problem

With EPR filings due in a matter of days, the brand teams were concerned about the forecasted exposure before submission. CMC classifications had been developed internally without independent verification against the CalRecycle CMC Guide, and they applied the same obligation assumptions across the board. No third party had reviewed either brand's supply data before submission.

Our impact

Engaged 10 days before the filing deadline, we conducted parallel audits across both brands and all three states. Validated reductions were identified in every state for both brands.

For the smaller brand, a CMC reclassification driven by film composition analysis and a closer examination of producer hierarchy produced a combined fee reduction of approximately 24% against the expected filing total.

For the larger brand, state specific carveouts of transport materials and a CMC reclassification produced validated reductions of approximately 2% against a significantly larger California-weighted fee base.

Every reduction was validated and defensible at filing.