Beyond Packaging: EPR’s Data Demands for Personal Care Artwork

Intertek's Assurance in Action Podcast Network

Welcome to the Intertek Podcast Network, Assurance in Action, your hub for quality insights and information from our Intertek experts. Learn what our people are saying about important industry trends ranging from food safety standards to supplier management and everything in between! With new and recurring guests, we are poised to provide you the knowledge needed to enhance your business processes, operations, and safety.

All Episodes

Intertek's Assurance in Action Podcast Network

Beyond Packaging: EPR’s Data Demands for Personal Care

August 28, 2025 • Intertek • Season 8

Data is the new currency of compliance. In today’s episode, we’re diving into the data management strategies companies need to meet Extended Producer Responsibility (EPR) regulations, and what this means for the personal care industry. From navigating requirements across the U.S. to staying ahead of international mandates, we’ll share how we’ve been helping clients in personal care and consumer goods build the systems and processes to stay compliant and competitive. Tune in to learn how smart data management can turn regulatory challenges into business opportunities.

Presenters:
Thomas Savarese, Compliance Manager, Regulatory Market Access, Intertek Assuris
Ashli Span, Project Manager, Regulatory Market Access, Intertek Assuris

Beyond Packaging: EPR’s Data Demands for Personal Care

00:16 --> 02:01
Speaker 1 – Thomas Savarese, Compliance Manager, Regulatory Market Access, Intertek Assuris

Welcome back to Intertek’s Assurance in Action podcast!

My name is Tommy Savarese and I’ll be your host for this episode.

Today’s topic is the data management needed to comply with Extended Producer Responsibility, or EPR, regulations and the effect of these regulations on the personal care industry. We have been assisting many clients in the personal care and consumer goods industries to collect and store the data needed to comply with the various EPR regulations both in the US and internationally.

EPR requires companies that manufacture and/or sell products and packaging products to be financially and operationally responsible for the end-of-life of these products. Each EPR policy program bill differs in its implementation and requirements including whether producers are individually responsible or if they are required to join a PRO or Producer Responsibility Organization. Bills and proposals may also vary in financial responsibility or degree to which a producer assumes responsibility, fee structure, and/or enforcement of the bill through reporting requirements and penalties. The goal of EPR is to incentivize material and design decisions that favor reduced environmental impact. EPR was first introduced into law in the EU in the early 1990’s, but this trend is growing significantly, with several countries adopting new EPR regulations worldwide.

EPR is gaining a lot of momentum in 2025. As of today, 12 states have introduced legislation on EPR for packaging, and 7 states have passed EPR bills. We are excited to dive deeper into this topic today. With me is my colleague, Ashli Span.

02:01 --> 02:15
Speaker 2 – Ashli Span, Project Manager, Regulatory Market Access, Intertek Assuris

Thank you, Tommy That’s right. We are hearing more and more about EPR in our working groups, conferences, and of course from our clients who are looking for support to comply – and keep up with – new legislation.

02:16 --> 02:21
Speaker 1 – Thomas Savarese, Compliance Manager, Regulatory Market Access, Intertek Assuris

Let’s start with the why. Why are we seeing more legislation and efforts going into EPR programs here in the US?

02:21 --> 02:43
Speaker 2 – Ashli Span, Project Manager, Regulatory Market Access, Intertek Assuris

Other regions, including the EU and Canada, have well-established EPR regulations for packaging. And there are EPR programs in some states for products like paint and electronics. But with growing recycling costs, the plastic pollution problem, and an overall demand for more environmental accountability, there is more interest than ever before in the US for EPR laws.

02:43 --> 02:50
Speaker 1 – Thomas Savarese, Compliance Manager, Regulatory Market Access, Intertek Assuris

Absolutely. I can imagine this will present some challenges for producers. Are there any other incentives built into the laws?

02:50 --> 03:07
Speaker 2 – Ashli Span, Project Manager, Regulatory Market Access, Intertek Assuris

Ultimately, EPR requires, to some extent, producers to pay the net costs of the collection, sorting, recycling, and disposal of household packaging. Some EPR laws will lower fees if they use a high level of recycled content, eco-design, or renewably sourced materials.

03:07 --> 03:14
Speaker 1 – Thomas Savarese, Compliance Manager, Regulatory Market Access, Intertek Assuris

So, what is the effect of these laws on businesses? And the perquisites of EPR regulations long term?

03:14 --> 04:04
Speaker 2 – Ashli Span, Project Manager, Regulatory Market Access, Intertek Assuris

For businesses, this marks a significant change in operational and financial responsibility. The most immediate impact will be on companies that generate significant amounts of packaging, such as retailers, manufacturers, and importers. These businesses will now need to report on the type, weight, and material composition of their packaging, ensuring it is recyclable or, in some cases, reusable. This will likely drive innovation in packaging design and materials, encouraging the use of more sustainable alternatives to reduce costs associated with disposal.

In the long term, EPR regulations are expected to boost recycling rates, reduce waste, and encourage the development of a circular economy. Companies that proactively adapt to the regulations could gain a competitive advantage by showcasing their commitment to sustainability and eco-friendly practices.

04:04 --> 04:13
Speaker 1 – Thomas Savarese, Compliance Manager, Regulatory Market Access, Intertek Assuris

I can definitely see how these regulations could reduce waste and increase the amount of products and packaging that is recycled. Are there any fines associated with non-compliance?

04:13 --> 04:31
Speaker 2 – Ashli Span, Project Manager, Regulatory Market Access, Intertek Assuris

Yes, there are. Fines for non-compliance can reach tens of thousands of dollars. And with individual States having different regulations, you will have to keep and maintain a sound record and update the amount of product being released.

04:31 --> 04:41
Speaker 1 – Thomas Savarese, Compliance Manager, Regulatory Market Access, Intertek Assuris

I see. Let’s go over some of the requirements of EPR laws. Of course they will vary by State, but what are some of the more common or general expectations for producers?

04:41 --> 05:02
Speaker 2 – Ashli Span, Project Manager, Regulatory Market Access, Intertek Assuris

Yes, they will vary, but all brands will have to track and submit data on materials used, and pay fees based on the sustainability of their product packaging. For this, they will need to know the recyclability, reusability, compostable status, and source information. And lastly, they will need to meet recycling targets, which also vary by State.

05:02 --> 05:06
Speaker 1 – Thomas Savarese, Compliance Manager, Regulatory Market Access, Intertek Assuris

How are companies going to go about tracking this information?

05:06 --> 05:39
Speaker 2 – Ashli Span, Project Manager, Regulatory Market Access, Intertek Assuris

Well, that depends on the brand or producer. But we certainly have clients needing help with the data collection, tracking, and management. We can work directly with packaging manufacturers and third-party manufacturers to collect the necessary information for compliance.

Managing this data presents one of the main challenges for producers. Maintaining a solid system of record, having a well-established method for data collection and an understanding of how to determine recyclability and calculate packaging component information, all will make compliance much easier.

05:39 --> 05:43
Speaker 1 – Thomas Savarese, Compliance Manager, Regulatory Market Access, Intertek Assuris

Yes, and this is something we can help with, correct?

05:43 --> 06:26
Speaker 2 – Ashli Span, Project Manager, Regulatory Market Access, Intertek Assuris

We can! We have worked with personal care companies to ensure they have all of the information they need to accurately track the different components in their packaging. This includes reaching out to their packaging suppliers to get specific information on what the products they provide are made up of.

There are many different types of packaging and these different packaging types can all be used in the same product in some instances. For example, a tube of lipstick may be made of polypropylene with an inner layer of polyethylene. This tube may be packaged in a paper carton. All of the different types of packaging must be accounted for, tracked, and submitted to comply with many of these EPR regulations.

06:26 --> 06:29
Speaker 1 – Thomas Savarese, Compliance Manager, Regulatory Market Access, Intertek Assuris

Wow! Once you gather this information, what do you do with it?

06:29 --> 06:47
Speaker 2 – Ashli Span, Project Manager, Regulatory Market Access, Intertek Assuris

It depends on the client, but generally the data is recorded into an internal database. When it is time to report, they have all of the information they need in one place.

Since we are already requesting this information, our group generally enters this information into their database. We have found this process to be the most efficient.

06:47 --> 06:52
Speaker 1 – Thomas Savarese, Compliance Manager, Regulatory Market Access, Intertek Assuris

If the packaging suppliers change their raw materials, will this change the data that is needed to comply?

06:52 --> 07:07
Speaker 2 – Ashli Span, Project Manager, Regulatory Market Access, Intertek Assuris

Yes, changes to the raw materials of the packaging could change what a company needs to report. This is why it is very important to have clear communication up and down the supply chain. Depending on the packaging change, this could end up saving the company money.

07:07 --> 07:16
Speaker 1 – Thomas Savarese, Compliance Manager, Regulatory Market Access, Intertek Assuris

That’s great! Would you be able to go into more specifics about what the data collection and management process might entail? What type of information do you generally request?

07:16 --> 08:11
Speaker 2 – Ashli Span, Project Manager, Regulatory Market Access, Intertek Assuris

Sure!

So, first we would want to gather key data which includes;

1. Is it a primary, secondary, or tertiary component?

2. What is the material type; plastic, paper, or other? And a breakdown of the percentages of each.

3. Weights of each packaging component

4. Pre- and post-consumer recycled content

5. Then we need to determine the recyclability of the material

6. Lastly, if the material is sustainably sourced – i.e. FSC certified paper products – and the percentage should be tracked.

We will work with packaging suppliers across the supply chain to gather this data and make sure that companies have everything they need, depending on the various material types: plastic, paper or other mixed-material types. It can get complicated, but we have designed systems to help gather and track this data.

08:11 --> 08:18
Speaker 1 – Thomas Savarese, Compliance Manager, Regulatory Market Access, Intertek Assuris

How difficult is it to obtain this information from the packaging suppliers? Are they generally quick to respond?

08:18 --> 08:37
Speaker 2 – Ashli Span, Project Manager, Regulatory Market Access, Intertek Assuris

It depends on the sophistication of the supplier. As more EPR regulations are passed, the more the packaging manufacturers need to be aware of what information their customers will need in order to comply. Forming a good relationship with your packaging suppliers is extremely important to ensure you have all of the up-to-date information required.

08:38 --> 08:47
Speaker 1 – Thomas Savarese, Compliance Manager, Regulatory Market Access, Intertek Assuris

It seems as though there are other regulations for cosmetic packaging that can come into play as well. Do you recommend asking for this information upfront as well?

08:47 --> 09:16
Speaker 2 – Ashli Span, Project Manager, Regulatory Market Access, Intertek Assuris

Absolutely. Personal care companies also need to ensure their product and packaging is compliant with California Prop 65 and fulfills the safety requirements of MoCRA. Asking for all of this information at once can save a lot of time and help prevent unneeded, repeat conference calls and emails with suppliers.

It is also important to know what questions to ask and, while reviewing the provided information, do not be afraid to ask questions if something is unclear.

09:16 --> 09:29
Speaker 1 – Thomas Savarese, Compliance Manager, Regulatory Market Access, Intertek Assuris

That makes a lot of sense. You mentioned that determining recyclability is a part of this process; is this something Intertek can help with as well? I know there is a lot of variation in its definition, even State-by-State.

09:29 --> 09:47
Speaker 2 – Ashli Span, Project Manager, Regulatory Market Access, Intertek Assuris

This is a great point. Like EPR laws, the industry is pushing for harmonized recycling regulation across the US. However, our group can determine this using an internal process aligned with the regulatory definitions both in the US and the EU, even without this harmonization.

09:47 --> 09:58
Speaker 1 – Thomas Savarese, Compliance Manager, Regulatory Market Access, Intertek Assuris

So, ultimately, if a company is having difficulty collecting, tracking, and/or managing their EPR data, including determining recyclability, we can offer full support?

09:58 --> 10:17
Speaker 2 – Ashli Span, Project Manager, Regulatory Market Access, Intertek Assuris

Absolutely, we have a dedicated regulatory group, a team well-versed in the sustainable packaging sector, and a global network of experts and scientists to connect all the dots. We have a full staff ready to complete supplier outreach and even enter the data into a company’s internal database to ensure the data you need to comply is accurate and available.

10:17 --> 10:24
Speaker 1 – Thomas Savarese, Compliance Manager, Regulatory Market Access, Intertek Assuris

That’s great! Thank you, Ashli for joining today.

10:24 --> 10:25
Speaker 2 – Ashli Span, Project Manager, Regulatory Market Access, Intertek Assuris

Oh, it was my pleasure.

10:25 --> 10:45
Speaker 1 – Thomas Savarese, Compliance Manager, Regulatory Market Access, Intertek Assuris

That’s all for today’s episode. As EPR requirements expand and data becomes the backbone of compliance, the question isn’t if companies will adapt – its how quickly. We’ll be back with more strategies and insights to help you stay prepared. Until then, keep asking the tough questions and pushing for smarter solutions.