If a producer sells to a large chain store and the chain store distributes to its stores around the country, how is the producer supposed to know how much was sold in each relevant state?
This one is an absolute classic of EPR policy and basically we’re all facing it. It is allowable to estimate just based on the state’s population (Oregon is ~1.2% of US population, therefore we allocate 1.2% of all our packaging there). However, of course, this could be wildly inaccurate and you could pay and report too much.
This is the way we’ve been approaching it as a large producer. Unfortunately, getting to sales level data sold within the state is a challenge. I hear that someday only sales level data will be acceptable. We could have distribution centers who distribute products for sales in other states - tracking this information is really difficult.
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Yes, it’s the challenge of our times. Hopefully some data infrastructure builds up around it, with POS info that can be shared, possibly from Shopify or something like that.
In lumber, we are talking to The Home Depot and Lowes and do have some sell through info, but don’t have it with perfect accuracy, so we are doing a conservative (high) estimate. I can’t imagine how we would ever know it perfectly, since a typical deck job could include a bill of materials shipping from several different sites, some DTC, some through wholesale to the contractor, and some retail to the homeowner.
@Marty the problem with retailer POS data is that supply reporting requires materials shipped into the state, not retail sales data. In the case of Shopify, that’s a good methodology for DTC e-commerce shipments. I think the population based estimation is the best practice for when the actual data doesn’t exist.
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Fair points. I think the key at this point, 4 days from the reporting deadline, is to get something in, and explain how you got there in the Methodology section. You can then do better (and thus reduce fees, if your refined data shows a reduction) in future years.