Inside Just Born's Approach to EPR Reporting and Packaging Data: Packaging World

What happens when a packaging engineer becomes a company's entire EPR function—with no dedicated team, no enterprise software, and just Excel?

Senior Editor Anne Marie Mohan sits down with Charlotte Ashcraft of Just Born Quality Confections. Ashcraft shares how she built a state-by-state EPR compliance model from the ground up, starting with a summer-long physical audit of the company's packaging portfolio. She explains how that spreadsheet evolved from a reporting tool into a forecasting and planning system, and how AI tools now help her make sense of new state legislation in minutes rather than hours.

Read the full featured article on Packaging World.

Transcript

SPEAKER_00 0:03

Welcome to Through the Line, a podcast exploring innovations and information across the packaging and processing landscape. From topics impacting consumer packaged goods and healthcare packaging to the latest technologies in food processing operations.

SPEAKER_01 0:22

Hello, I'm Anne-Marie Mohan. I'm with Packaging World. And I'm here today live at the Packaging Recycling Summit, which is a packaging world event. And I'm here with Charlotte Ashcraft. She's the senior manager of packaging and graphics development at Justborn Quality Confections. And Charlotte just got off the stage talking about how JustBorn started working through the EPR process at her company. And she's going to share that with us a little bit here. So welcome, Charlotte. Thank you for having me. I appreciate it. And thank you for your wonderful presentation. I think one of the really relatable points you made was that when you started, you really spent so much time trying to understand all these different policies and what was different, you know, what was the same. And there are so many different different nuances to these different legislations. But then it became more of a question of packaging data. So for those CPGs that are still trying to understand what EPR means for their business, could you describe more about when that shift came?

SPEAKER_02 1:31

Yeah, so I think you're exactly right. And I mentioned it on stage, but I approached this by just trying to understand every nuance, every regulation, every state difference, attend every webinar, and it was so overwhelming. And when I really felt like I had a good grasp on what was happening, something else would change. So I think once I finally took a step back and was like, okay, what are all of these states really truly asking? I realized all of them were asking for some version of the same information. And that really needed to come from our packaging data. So I think once I had that realization is really when everything shifted for us.

SPEAKER_01 2:08

Okay. And you talked about the fact that companies don't have to wait until they have a perfect system or they have a full EPR team to get started. What were some of the first data points you knew you had to get under control and where did that information live inside the company?

SPEAKER_02 2:26

Yeah, so we really needed two main data points, and that was our sales volume and our packaging weight by component. And for the sales volume, we're actually using the population-based method, not because it's perfect, but because it's transparent and it's consistent, and it just makes things a lot easier because we lose the chain of custody on our products when it hits our customers' distribution center. So we're using the population method, and that's one data point that we need. And then we really needed to pull together our packaging weight by component. And at the time when you know EPR was really starting to emerge a few years ago, we did not have a clean source of all of that information. It lived in various places, different specifications. Some had, some were just with our suppliers, some were in documents that couldn't even be opened in a modern version of Microsoft anymore. So everything was completely scattered. And I also didn't trust the Nambit was correct because we had made so many changes. I've been there 10 years, and there were some documents I had never even opened, and I knew how much had changed since I had been there. So we really needed to start by just completely wiping the slate clean and starting fresh. So I actually had an intern a few years ago, and she came in and completely audited our whole packaging portfolio. And it seems so monotonous, but it was the most important part of this process was making sure that we trusted our data and that the data was really correct.

SPEAKER_01 3:45

So she audited all of that, and that's how we built out the whole database. Okay. And you talked about the spreadsheet that you're using, and you said, you know, it's nothing fancy, it's an Excel spreadsheet. But could you talk a little bit more about that, that model? And you talked a lot about some of the things that you were able to see once you had all that data in that spreadsheet that you weren't able to see before, and that became more clear to you. Could you talk a little bit about that too? Sure.

SPEAKER_02 4:15

Yeah, so you're right. It's really nothing fancy. It's just taking our state volume, so the prorated value of our annual volume, and multiplying that by a standardized weight per case. So the way I'm creating that standardized weight per case is I'll take our primary packaging and multiply that by the case count, and that tells me how much primary packaging is in each case. And then if a state collects tertiary packaging or transport packaging, I'll divide that by the pallet count. And that's how I allocate a portion of those materials also to each case. So then I can add my primary packaging materials, secondary, and unit load all into one and create one kind of standardized version. So I can take that number and multiply it by the prorated value of our volume in each state, and that generates how much of each material type I'm creating. And I keep all of those separate until the very end of the spreadsheet. So that way I can manipulate much easier for each state when a new state comes on board. So I don't add all of the fiber-based materials until I get to the very end. Because if a state wants corrigate separated from paperboard, I don't want to have to go back and separate those eventually. So I don't add them till the end.

SPEAKER_01 5:21

I think was that all of the questions that you had? Well, we talked a little bit, or you talked more about once you had all that data spread out before you that you were able to then use it as like a forecasting thing. Yeah, that's so good point.

SPEAKER_02 5:36

Yeah. So once we had that, I was able to see, you know, what materials are not recyclable today. And that's really kind of the heart of what we need to do for SD54 in advance of 2032 and all of the planning work that we need to do. So I can see what parts of our portfolio are going to be much more challenging to change over than others, and I can start using that to plan out the validation work. So the much more challenging projects, we need to start those now. Whereas the much easier projects that are we already have some sort of substrate that's viable, we can hold those off until we're done with the validation work on the more challenging ones. So that's how we're using it for a lot of our long-term department planning.

SPEAKER_01 6:14

Okay, okay. And you mentioned too something that I think is probably common with a lot of CPGs, and that is the struggle with the chain of custody issues. You know how much you're putting out in the market, but you may not know exactly state by state where things end up. And so how did you approach that gap and what makes an assumption defensible? You talked about this.

SPEAKER_02 6:40

Yeah. So we're just using the population method and it's defensible because it's transparent and it's consistent. So if I'm consistent across every state, I think that is much more defensible than, well, I think it might be this for California and I think it might be that for Oregon. So if it's truly transparent and it's based on publicly available data, that's what means defensible for me. And for anyone who hasn't submitted an EPR report, you actually have to list out your entire justification on how you came up with those volumes within your report when you're submitting to the CAA. So I'm able to describe that very easily, my methodology for the calculations.

SPEAKER_01 7:17

Okay. And for CPGs out there, you said, you know, it doesn't have to be perfect. You just have to get started. So what is the most important thing you would advise that they get started with? And just as important, what should they not waste their time with during that first year, their first reporting cycle?

SPEAKER_02 7:35

I think the most important thing is if you don't have your data, find data that you do trust and figure out what data you need to create. Because if you don't have that data foundation, you can't trust your model or your formulations or your outputs, and then therefore your fees are incorrect. So I think really just starting with the data foundation and making sure you trust it is where you need to start. I would not try to understand every regulation because you know, once you have that foundation that I'm talking about, you can derive almost anything that you need out of it. And so start with the foundation, don't try to understand everything because you'll also burn yourself out and overwhelm yourself, as I did initially. Let's start with that. And, you know, don't try to cast a net too wide, but cast the net that you know you can control.

SPEAKER_01 8:22

Okay. I think that was one of the biggest learnings I got out of your presentation was that the ins and outs of every policy, those aren't as important to understand. It's getting that data, and then you can plug it in where it needs to be plugged in. Yeah. I've seen so many eye charts with you know, it's this in this state and this in this state. So excellent advice. Yeah. So thank you so much for thank you for having me.

SPEAKER_00 8:52

I appreciate it. Thank you for listening to Through the Line Packaging and Processing. You can listen to more episodes on all streaming platforms. Be sure to visit us at packworld.com, profoodworld.com, and healthcarepackaging.com for more packaging and processing news. This podcast was edited by Brady Guns.