How to weigh your packaging for a CAA report (and what CAA accepts)
The Circular Action Alliance (CAA) annual supply report asks for pounds of packaging per material category for each state, and for a written account of how you got them. CAA's guidance puts the methods in order: weighing the actual packaging of each product is preferred, a randomly chosen sample per group of similar products is the fallback, and industry-norm estimates are only for real data gaps. For most small brands that means taking one unit of each product apart and weighing every piece. This guide quotes what CAA says, gives a step-by-step procedure, and has a free spreadsheet template.
A practical how-to, not legal advice. CAA's own guidance and the CAA Reporting Policy govern how you report. The quotes below are from CAA's "Preparing to Report Your Supply Data" (version 1, dated November 27, 2024) and its Reporting Policy (version 2.0, June 2026). CAA's current guidance in the Producer Portal can be newer, so check it before you file.
The methods CAA accepts, in CAA's order
Specific Material Reporting Method (SMRM): weigh each product's actual packaging. CAA describes it as "calculating and reporting the exact weight of each individual packaging component and paper product, categorized by material type". It says: "This method is the preferred approach for preparing data for the annual producer report submitted to CAA", and "In future reporting periods, the use of the Specific Material Reporting Method will be strongly encouraged to ensure data accuracy and compliance." You multiply each component's weight by the units supplied into the state.
Average Bill of Materials (ABOM): weigh a sample from each group of similar products. CAA calls it "a practical approach for producers who supply a wide range of products and covered materials but lack readily available data on the types or weights of individual packaging and paper materials." It "relies on representative sampling strategies within groups of products that share similar packaging formats and attributes". The sample is weighed physically, and "The sample used to represent each of the sub-groups should be selected randomly from all eligible products included within the sub-group." Each sample's weights are then averaged by each sub-group's share of units sold.
Sector calculators: industry-norm estimates, for data gaps only. CAA doesn't provide them. It defines them as "tools that estimate packaging weights based on industry norms" and says they are "generally less accurate than SMRM or ABOM methodologies". In CAA's words, "They should be relied upon only in cases of significant data gaps where other reporting methodologies are not feasible. Producers using sector calculators must disclose the methodologies applied, including details of any assumptions or averages used, as part of their reporting submission." And: "the use of sector calculators may not be permitted indefinitely."
The Reporting Policy v2.0 adds the rules around them (section 3.5):
"Multiple methodologies may be used within the same Producer Report, provided they are properly documented."
"Accepted methodologies are outlined in CAA producer guidance and must be disclosed in the Producer Report. CAA does not preapprove individual producer methodologies."
"Participants that do not use CAA's Accepted Reporting Methodologies must include in their report submission an explanation of why their chosen methodology is a more accurate approach to determine their supplied data."
When CAA validates a report, its methodology assessment checks that the method "adheres to CAA's Accepted Methodologies, or is more accurate, and is consistently applied" (section 3.10). If you have a few dozen products or fewer, weighing every one is usually quicker than building sampled groups, and it's the method CAA prefers.
How to weigh: step by step
List every product you supplied in the data year. For the 2027 report that's calendar 2026. One row per SKU. If several SKUs use identical packaging (same bottle, cap, label and box, with only the scent or flavor different), weigh one and note in your records that the others share it.
Take one unit of each SKU apart. Empty it, rinse or wipe out any product, and let it dry. Separate only the pieces a customer would separate: a cap, pump, lid, insert or tear-off sleeve is its own component; a label glued to a bottle stays on it and is weighed with it. That follows CAA's separable and non-separable component rule, explained in our material categories guide.
Don't miss the small or outer pieces. Labels on cartons, seals, inserts and instruction leaflets, multipack wrap, and, if you ship the product yourself, the shipper box, tape and void fill. If one box ships several different products, it's simpler to track boxes and fill by box size and count than per SKU. First check whether you're the one who reports them: see who reports shipping packaging.
Weigh each component to the gram on a scale. A kitchen or postal scale that reads in 1 g steps is enough for most pieces. Zero (tare) it first and check it against something of known weight. For pieces lighter than about 10 g, such as caps and labels, weigh 10 together and divide by 10, or use a pocket scale that reads in 0.1 g steps. Record grams; you convert to pounds at the end.
Record the material. Note what each piece is made of and, for plastics, the resin code printed on it (PET #1, HDPE #2, PP #5 and so on). Say whether a plastic bottle is clear or colored, and note anything that changes the category, such as a plastic window or plastic tape on a paper box.
Choose the CAA category for each state. You choose it from each state's own list, so the same cap can have a different category name in Oregon, Colorado and California. Our material categories guide shows where each official list lives and works through a bottle, cap, label and box. Write down why you chose each category; it belongs in your methodology.
Multiply by units shipped into each state. Take units per SKU per state from your store, marketplace or 3PL reports, by ship-to address. Component grams × units = grams per component per state. Add them up by category and divide by 453.59237 to get pounds. CAA's Reporting Policy says producers "must retain all available decimal places in their data calculation until final submission" and must "use mathematical rounding to round final figures to two decimal places" (section 3.6).
Keep the records. Keep the spreadsheet, a photo of each component on the scale, the date, the scale used, the sales exports and your category notes. See below for why.
Example: a 32 g bottle with its label, shipped as 10,000 units into Oregon, is 32 × 10,000 = 320,000 g, and 320,000 ÷ 453.59237 = 705.48 lb in "PET (#1) - Bottles, Jugs, and Jars (Clear/Natural)". The product and weights are made up for illustration.
If you have many SKUs and can't weigh them all, CAA's ABOM steps are: group products with similar packaging into sub-groups, pick a sample product at random from each, weigh its packaging, weight each sample by its sub-group's share of units, and multiply the averages by total units. Write down how you grouped and how you picked the samples.
One row per packaging component per SKU. It opens in Excel, Google Sheets or Numbers. The three rows starting EXAMPLE- are examples (a soap bottle with label, its cap and its shipper box); delete them before you use it. The columns:
sku: your SKU code.
product: the product name.
component: the piece, such as "bottle with label", "cap" or "shipper box".
material: material and resin code, such as "PET #1 clear" or "corrugated cardboard".
weight_g: grams per unit. Decimals are fine.
level: primary, secondary or shipping.
estimated: yes if the weight isn't measured or from a supplier specification, otherwise no.
source: where the weight came from, such as "measured 2026-10-04, 1 g scale", "supplier spec sheet", or the basis for an estimate.
The template has no category column, because one component takes a differently named category in each state. Keep a second short list with one row per material and state: material, state, category. Mark every estimate, so you can list it in your methodology: CAA requires the methodologies behind your numbers to be disclosed, and for sector calculators that includes "details of any assumptions or averages used". Keep your units by state in a third list: sku, state, units. These are the same formats we use for paid report prep.
Keep the records: what CAA can ask for
CAA's guidance says "producers must submit all methodologies used for data preparation" and that "Upon request, producers may be asked to provide additional calculations, substantiation for updates, or estimates to confirm the data's reasonability." The Reporting Policy defines substantiation as including "surveys, studies, spreadsheets, calculations, images, or other documentation", and says "Participants are responsible for providing reasonable, transparent, and verifiable data". If CAA follows up, it can "Request Substantiation, including but not limited to supporting records, calculations or documentation to validate reported data."
Keep: the component spreadsheet, photos of each piece on the scale, the date and scale used, the sales exports by state, your category decisions, and the methodology text you submitted.
How long: we didn't find a retention period in the Reporting Policy. Producer adjustments can be requested up to 24 months after the report date, and the policy says finishing a validation "does not prevent CAA from conducting further audit or investigation", so keep them well beyond that.
Pick your method before you file. "Reports may not be amended solely to change the reporting methodology or allocation approach used to calculate supplied quantities." Replacing an estimate with measured data is allowed as an adjustment.
What to write in your methodology
Which method you used for which products: measured weights (SMRM) for which SKUs, sampled averages (ABOM) for which groups, and how you grouped and sampled.
How you weighed: the scale, its resolution, the dates, and how you handled small pieces.
Every estimate: which components, how much weight, the basis, and why you couldn't measure.
Where the units by state came from, and any apportionment.
How you decided separable components and categories.
That you kept all decimals and rounded only the final pounds to 2 decimal places.
The CAA annual supply report guide covers what else goes in the report, the expected June 1, 2027 date and the charges for inaccurate reporting.
Need the numbers for your report? We turn your product catalog, packaging and sales into pounds per category for each state, with a written methodology. Email hello@eprhelp.com with your states and roughly how many products you sell, and we'll reply with a fixed quote.