New GS1 US Guidance Gives Supplement Manufacturers a Data Framework for Extended Producer Responsibility Compliance

GS1 US, the not-for-profit global data standards organization that administers the Universal Product Code barcode system, published a new guidance document designed to help companies across healthcare, retail grocery, foodservice, apparel, and general merchandise prepare for state-level packaging extended producer responsibility requirements.¹

The resource, developed by the GS1 US Cross-Industry Extended Producer Responsibility Workgroup, is known as the “GS1 US Guidance for Extended Producer Responsibility (EPR) Packaging Requirements”² and addresses what has become one of the more underestimated compliance burdens for finished product manufacturers: not simply whether they are subject to these laws, but whether their internal data infrastructure is capable of meeting the detailed packaging reporting those laws require.

“EPR requirements are evolving quickly and vary by state, creating new complexity for producers,” said Michelle Covey, GS1 US’ vice president of customer success. “This guideline helps organizations take a practical, standards-based approach to managing packaging data so they can meet regulatory requirements more efficiently while also supporting broader sustainability and circular economy goals.”

Nutraceutical and dietary supplement manufacturers might argue that the timing is consequential. Seven states have enacted packaging extended producer responsibility laws:

1. California
2. Colorado
3. Maryland
4. Maine
5. Minnesota
6. Oregon
7. Washington

Meanwhile, legislators in Wisconsin and New Hampshire introduced additional bills in late 2025 and early 2026.³ Washington's law requires producers to register with a Producer Responsibility Organization (PRO) by July 1, 2026, while California's fee obligations begin in 2027. Non-compliance with these laws can result in fines, loss of market access, and liability under consumer protection statutes.⁴

What Does the GS1 Guidance Actually Require Companies to Do to Prepare for Extended Producer Responsibility?

Under extended producer responsibility frameworks, producers, typically the brand owner or importer whose name appears on packaging, must collect and report detailed packaging information to a designated PRO. That body manages collection, reporting, and funding obligations tied to packaging at end of life. The definitions of covered materials, covered producers, and reporting timelines vary by state, creating a fragmented compliance landscape for nationally distributed brands.³

The GS1 US guidance focuses on the data infrastructure layer of that compliance challenge. It demonstrates how companies can use GS1 identifiers, specifically Global Trade Item Numbers and Global Location Numbers, alongside defined product and packaging attributes to identify products and packaging at multiple levels across the supply chain, capture material composition, weight, and sustainability information consistently, share data with trading partners in a standard format, and reduce errors in extended producer responsibility reporting.

Sector-specific direction is also provided. The guidance addresses how healthcare companies can manage packaging data for retail medical products, and how foodservice companies can communicate data for single-use items and paper products.

By using a consistent data structure, the guidance notes, companies can improve supply chain transparency and manage extended producer responsibility requirements more efficiently as new state programs are introduced.

Why Is Packaging Data Management a Specific Compliance Challenge for Supplement Companies?

Dietary supplement and nutraceutical products frequently involve multi-component packaging structures, such as primary containers, secondary cartons, inserts, and tertiary shipping materials. Each of these may be subject to separate reporting requirements depending on material type and state jurisdiction. Brands may lack the internal systems needed to capture packaging material weights, composition classifications, and recyclability data in a form that can be efficiently reported to a PRO.

A 2025 analysis published in Nutritional Outlook⁴ specifically addressing food and dietary supplement companies noted that extended producer responsibility "isn't a passing trend—it's a regulatory and business reality," and that brands positioning early would be better placed to manage compliance costs and regulatory requirements as state programs mature.

The GS1 US guidance addresses this readiness gap directly by providing a structured, industry-neutral data model applicable across state programs — an important consideration for supplement companies that distribute nationally and face overlapping state obligations simultaneously.

What Limitations and Open Questions Should Manufacturers Keep in Mind?

The GS1 US guidance is a voluntary framework, not itself a regulatory requirement. Compliance with extended producer responsibility laws is determined by individual state statutes and the rules of each state's designated PRO. not by whether a company has adopted GS1 data standards. Manufacturers should not treat implementation of this framework as equivalent to legal compliance, and should consult legal counsel and engage directly with applicable state programs and Producer Responsibility Organizations to understand their specific obligations.

The state extended producer responsibility landscape also continues to evolve. Requirements, fee structures, reporting deadlines, and covered material definitions are not uniform across enacted laws and remain subject to revision as programs mature. Several of the seven enacted state programs are still developing their operational frameworks, meaning specific reporting requirements may not be fully defined for all markets at the time a company begins compliance planning.³ Manufacturers operating across multiple states should maintain current awareness of each jurisdiction's specific obligations rather than assuming a single compliance posture will meet all requirements.

References

1. GS1 US publishes guidance to help companies prepare for extended producer responsibility packaging requirements. GS1 US. June 2, 2026. Accessed June 15, 2026, https://www.gs1us.org/industries-and-insights/media-center/press-releases/Guidance-To-Help-Companies-Prepare-for-Extended-Producer-Responsibility-Packaging-Requirements

2. GS1 US guidance for extended producer responsibility (EPR) packaging requirements. GS1 US. May 30, 2026. Accessed June 15, 2026. https://documents.gs1us.org/adobe/assets/deliver/urn:aaid:aem:9a645452-7078-497c-8b4e-7be9e324da2d/gs1-us-guidance-epr-requirements.pdf?_gl=1*x3c71r*_gcl_au*MTE3NzkyMTM5My4xNzgxNTQ3Mzk4

3. Hogan Lovells. Extended producer responsibility for packaging in the United States: key elements and considerations. Hogan Lovells. February 16, 2026. Accessed June 15, 2026. https://www.hoganlovells.com/en/publications/product-extended-producer-responsibility-for-packaging-in-the-united-states-key-elements

4. Talati AR, Patel N. Navigating the new wave of packaging regulations. Nutritional Outlook. August 21, 2025. Accessed June 15, 2026. https://www.nutritionaloutlook.com/view/navigating-the-new-wave-of-packaging-regulations