For small manufacturers and brands. We take your parts list, packaging specs, supplier contacts and sales by state once, keep them current, and reuse them for every report: customer declarations (CMRT/EMRT, REACH/RoHS, TSCA and Minnesota PFAS) and state packaging EPR reports for Oregon, Colorado and California. You review, sign and submit. We never sign, certify or submit for you.
Get started Do I have to file EPR?
AI helps with the drafting. A person reviews every report before you see it.
Send SKUs and parts, bills of materials, packaging components with weights, supplier contacts, and units sold by state. Spreadsheets are fine. We record every gap as "unknown".
We chase suppliers for missing data and keep a single, versioned product record with an audit trail of requests, replies and changes.
Customer declarations and state EPR reports are drafted from the same record, so the answers stay consistent and nothing gets re-collected.
Your authorized person signs declarations and files EPR reports in the CAA portal. You stay the one who attests.
Forward your customer's questionnaire. We chase your suppliers, fill in the template from your product record, and mark every gap as "unknown". We don't guess.
Every company, part, person and supplier below is made up for illustration.
From: supplier.quality@example-oem.test To: you@example-partsco.test Subject: Annual conflict minerals + substance declarations, due in 30 days Hello Example Parts Co., Please send the following for part numbers EX-1001 (machined bracket) and EX-2040 (wire harness assembly): 1. Completed CMRT (current RMI version), company-level scope 2. REACH SVHC declaration against the current Candidate List 3. RoHS (EU 2011/65/EU + 2015/863) compliance declaration 4. Any intentionally added PFAS, by CAS number Regards, Supplier Quality, Example OEM Inc. (fictional)
Declaring company: Example Parts Co. (fictional) · Scope: Company · Status: Draft, not yet signed by the authorized representative
| Metal | Intentionally added? | Suppliers responded | Conflict-free policy? |
|---|---|---|---|
| Tin (Sn) | Yes | 3 of 4 | Yes |
| Tantalum (Ta) | No | 4 of 4 | n/a |
| Tungsten (W) | unknown | 2 of 4 | unknown |
| Gold (Au) | Yes | 3 of 4 | Yes |
| Metal | Smelter name (fictional) | Country | Smelter ID | Reported by |
|---|---|---|---|---|
| Tin | Example Tin Smelting Co. | Example country A | EX-SN-0001 | Supplier A (solder) |
| Tin | unknown | unknown | unknown | Supplier C (plating). Reply pending |
| Gold | Example Gold Refinery Ltd. | Example country B | EX-AU-0002 | Supplier B (connectors) |
| Tungsten | unknown | unknown | unknown | Supplier D (tooling). No response yet |
Gaps stay marked "unknown" until a supplier confirms. Smelter IDs here are placeholders, not real RMI IDs.
DRAFT: for review by Example Parts Co.'s authorized signatory. Not signed. REACH (EC 1907/2006) Article 33 declaration Parts: EX-1001, EX-2040 Based on supplier declarations received as of [date], EX-1001 contains no SVHC on the current Candidate List above 0.1% w/w. EX-2040: Lead (CAS 7439-92-1) is reported by Supplier C in the brass contact at an estimated 0.2% w/w of the article -> Article 33 info duty applies. Concentration: UNKNOWN until Supplier C confirms. RoHS (2011/65/EU incl. 2015/863) declaration EX-1001: Complies, per supplier test reports on file (refs in audit file). EX-2040: Lead in brass contact relies on exemption 6(c) per Supplier C. Exemption status confirmation: UNKNOWN. Pending. PFAS: No intentionally added PFAS reported by 3 of 4 suppliers. Supplier D: UNKNOWN (no response). Signature: ____________________ (Authorized representative, Example Parts Co.) Prepared by Product Compliance Desk. We do not sign or certify.
To: sales@supplier-d.example Subject: Quick request: CMRT + PFAS info for tooling inserts (PO EX-5531) Hi Jordan, I'm writing on behalf of Example Parts Co. Our customer needs updated compliance data for parts that use your carbide tooling inserts. Could you send: - Your current CMRT (any recent RMI version is fine) - Confirmation of whether any PFAS are intentionally added (CAS numbers if so) If you already use a portal or have a standard declaration pack, a link is perfect. We'd appreciate it by [date + 10 business days]. Thanks, [Name], Product Compliance Desk, on behalf of Example Parts Co.
To: quality@supplier-c.example Subject: Follow-up: lead content in brass contacts (part C-88) Hi Sam, Thanks for your RoHS certificate last week. Two small gaps remain: 1. Measured lead concentration (% w/w) in the C-88 brass contact 2. Confirmation that you rely on RoHS exemption 6(c) Also, your CMRT lists a tin smelter without a smelter ID. Could you add it, or mark it as unknown on your side? A short reply in this email is fine. Thank you! [Name], Product Compliance Desk, on behalf of Example Parts Co.
US TSCA section 8(a)(7): January 31, 2027 is the latest date EPA's PFAS reporting submission window can open. EPA may open it earlier. Once it opens, most reporters have six months, and small manufacturers that only import PFAS in articles get twelve months. Source: 40 CFR 705.20, eCFR. EPA has proposed changes, including an exemption for article imports. That proposal is not final.
Minnesota: Products with intentionally added PFAS have reporting duties under Minnesota law. See the Minnesota Pollution Control Agency for current deadlines and fees.
This is general information, not legal advice.
From the same product record, we work out packaging weight by material category for each state using your state sales. You get an annual supply report ready to review, and you submit it to Circular Action Alliance (CAA) yourself.
A quick first check against each state's small-producer thresholds. It isn't legal advice. Other exclusions may apply, for example if you supply no packaging into the state.
1 metric ton = 2,204.6 lb. Leave a tonnage field blank if you don't know it.
| State | Small-producer threshold (meeting either test exempts you) | Source |
|---|---|---|
| Oregon | Under $5 million gross revenue, or under 1 metric ton of covered products sold into Oregon. Associated companies are counted together. Exemption applies automatically. | ORS 459A.863(32); OAR 340-090-0860(6)3 |
| Colorado | Under $5,779,297 gross revenue (the inflation-adjusted limit as of July 1, 2026), or under 1 ton of covered materials into Colorado. | C.R.S. 25-17-713(1); 6 CCR 1007-2 Part 1 §1.8.23 |
| California | Under $1 million total gross sales in California. Not automatic: you register in CalRecycle's PEPRS system and apply. Recyclable/compostable packaging requirements by 2032 still apply. | CalRecycle; 14 CCR 18980.5.24 |
This uses a made-up brand, "Northfield Pantry Co." (fictional), with four SKUs. All numbers are invented. Edit any unit or weight figure and the totals update. Categories are simplified here. A real report uses each state's official covered-material category list.
Method: units × state sales share × grams per component, summed per category. 1,000,000 g = 1 metric ton and 453.592 g = 1 lb. CAA reports are filed in pounds.
First declaration free. Cancel anytime. One product data load is included in both plans.
Customer declarations: CMRT/EMRT, REACH/RoHS and PFAS, with supplier chasing, human review and your audit file. Your first declaration is free.
Everything in Starter, plus packaging EPR annual supply reports for Oregon, Colorado and California and TSCA PFAS reporting prep, from the same data. You submit.
| Provider | What you get | Public price |
|---|---|---|
| Product Compliance Desk (us) | Done-for-you declarations (Starter) plus OR/CO/CA EPR and TSCA PFAS prep (Plus); you sign and submit | $199/mo Starter, $349/mo Plus; first declaration free |
| Done-for-you declaration services | Customer compliance requests | About $500–$1,500/mo. Our estimate from Respondy and The 3TGs. Scope varies. |
| EPRfile | DIY EPR software: you categorize your own data | $299/state/yr, or $499/yr for CA, OR, CO and MN5 |
| Smarter Sorting | Done-for-you EPR reports | About $3,500 per state report6 |
Prices are taken from public websites as of October 22, 2026 and may have changed. CAA program fees are separate and billed to you by CAA.