The CAA Annual Supply Report in 2027: what it asks for and when
Producers registered with the Circular Action Alliance (CAA) report, each year, the pounds of packaging they supplied into each state in the prior calendar year, split by that state's material categories, together with a detailed written methodology, their brands and affiliates, and a signed attestation. The next report covers calendar 2026. CAA's default date is May 31, but May 31, 2027 is Memorial Day, so under CAA's policy the deadline moves to June 1, 2027 at 11:59 PM Pacific. CAA hasn't announced its 2027 calendar yet. The work is in the data, so start collecting it now.
What the report contains
Pounds supplied per state reporting category for the prior calendar year. Keep every decimal in your calculations and round the final figures to 2 decimal places.
A detailed methodology explaining how you got the numbers.
Your brands and all corporate affiliates, whether they're included in your report or report separately.
An attestation by your Primary Contact or Authorized Representative.
We found no public evidence that the portal accepts file uploads: producers appear to type total pounds per category, plus the methodology text. CAA's Excel workbook mirrors those screens. We're moderately confident in this; CAA could change it.
Each state has its own category list: about 60 categories for Oregon, 61 for Colorado, CalRecycle's covered material categories for California, COMAR 26.04.14.04 for Maryland, and 8 simplified classes for Washington and Minnesota. California also wants the number of plastic components.
Accepted estimation methods
SKU-level (SMRM, Specific Material Reporting Method): the actual weight of each packaging component of each SKU, multiplied by units supplied into the state. CAA prefers it and says it will be "strongly encouraged" in future periods.
Averages (ABOM, Average Bill of Materials): group similar products, randomly weigh a representative sample from each group, and weight by unit share. Acceptable where SKU data is lacking.
Sector calculators: allowed only for significant data gaps, must be disclosed, and may be phased out.
Population apportionment: if you don't have state-level sales, units in a state = (state population ÷ population of the states where the product sells in representative volume) × US units. Intended as a temporary option.
You can mix methods in one report if you document them. CAA does not preapprove methodologies, reviews them against prior years and benchmarks, and can ask for substantiation. Caps, pumps and other components meant to be removed go in their own categories; parts that can't be separated go in the category of the majority material by weight (Maryland uses majority by volume). Law firm Holland & Knight's review of the 2026 round put it bluntly: "A single-line methodology is not acceptable, nor is a template methodology copied and pasted."
Why accuracy matters
An inaccurate-reporting charge of up to $5,000 or the fees on the misreported material, whichever is greater. Reporting late counts as inaccurate reporting. It's waived if you find and correct the error within 60 days.
1% per month interest, compounded, on late payments.
After a notice of delinquency and a 3-month resolution period, CAA escalates to the state regulator.
You get one producer adjustment per report, within 24 months of the report date; methodology-only changes aren't allowed.
Dates around it
The portal opens about 2 months before the report date, where practicable.
Aim to finish by Friday, May 28, 2027, in case the rollover doesn't apply.
California's annual data report to CalRecycle on 2026 data is due July 1, 2027; CAA files it for its participants.
No state's 2027 report date has been officially announced yet.
What to do next: data to start collecting now
A SKU list for everything you sold in 2026, with brand names and any affiliates.
Component weights per SKU: bottle, cap, label, carton, shipper box, tape, void fill. Weigh them, or weigh a random sample per product group if you'll use averages.
Material for each component, so you can map it to each state's categories.
Units shipped into each state in 2026, by ship-to address from your store, marketplace or 3PL reports.
The count of plastic components if you sell into California.
A methodology document written as you go: sources, sampling, assumptions, gaps.
Backup files (spreadsheets, calculations, photos) for substantiation requests.
First, find out which states you report in. Many small brands are exempt in some states and not others.