Nine gates. Thorough verification at every stage.
Every engagement follows a structured 9-gate workflow. If deadlines are tight, we narrow the initial configuration scope rather than skipping verification steps. The end deliverable is a permanent, auditable data asset that your team can use across annual reporting cycles.
Our 9-gate delivery workflow
- 1. Scope & capacity confirmation:We begin by reviewing your corporate entities, brands, and sales distribution across California, Oregon, and Colorado. We evaluate filing deadlines against realistic timelines for document retrieval, physical sampling, and client sign-off, ensuring we only take on work we can thoroughly verify.
- 2. Engagement authority & data terms:We sign mutual non-disclosure and data-handling agreements before any sensitive files change hands. We formally record who owns legal determinations. That is in-house leadership or external legal counsel. We also establish clear authorization protocols before contacting any of your packaging suppliers.
- 3. Jurisdictional screening:We evaluate your distribution channels, state sales volumes, and revenue thresholds against current program rules. Any ambiguous legal questions regarding producer hierarchy or exemption criteria are documented and routed to your counsel for review.
- 4. Source file intake & secure archiving:We collect your product catalogs, state-level unit sales, CAD drawings, supplier spec PDFs, and packing slips. All incoming documents are logged with cryptographic hashes in a secure archive, ensuring original supplier records remain untouched and fully traceable.
- 5. Configuration mapping & gap analysis:Rather than managing hundreds of separate product SKUs, we group your catalog into unique packaging configurations. When component specifications are missing, conflicting, or outdated, we document them in an unresolved register and provide structured request templates for your procurement team to send to vendors.
- 6. Statutory category classification:We map each component to active reporting categories in California, Oregon, and Colorado. Classifications are based on physical characteristics: rigid versus flexible form, barrier layers, color, and closure types. We never rely on resin codes alone. Every mapping carries its citation and schedule version.
- 7. Calculation, dual reconciliation & QA:We compute category totals by multiplying state sales units by component tare weights. We then perform dual reconciliations: confirming that component math ties out to total reported mass, and ensuring sales figures reconcile with 3PL fulfillment records. Top fee components and manual overrides receive secondary quality review.
- 8. Client review & formal certification:We assemble a comprehensive sign-off package summarizing totals, schedule versions, assumption registers, and open items. Your operational and legal leadership review and certify the findings in writing before any report is finalized for portal submission.
- 9. Final archive & project close:You receive the complete workpaper package: the normalized bill of materials, multi-state mapping register, draft portal upload workbooks, and an audit trail. Temporary working copies are securely purged in accordance with our data-handling agreement.
Illustrative workpaper excerpt
The table below illustrates the structure of our Packaging Bill of Materials and State Mapping Register. Each physical component is cataloged with its tare weight, source evidence grade, and specific statutory classification. To see the same structure with live arithmetic, run the illustrative one-product demo. It uses researched weights times published OR/CO/CA-early rates. Unknowns are excluded, not guessed.
| Config ID | Component | Material / Form | Tare (g) | Evidence Tier | CA Category (14 CCR §18973) | OR Category (ORS 459A.863) | CO Category (HB 22-1355) | Status |
|---|---|---|---|---|---|---|---|---|
CFG-BEV-12OZ-01 | Can body (12 oz) | Aluminum, rigid | 13.20 g | Tier 1 (Spec PDF #AL-204) | Aluminum Containers (§18973.1) | Cat 101: Aluminum Cans | Cat B-01: Aluminum Rigid | Green |
CFG-BEV-12OZ-01 | Can end (202 lid) | Aluminum, rigid | 2.45 g | Tier 1 (Spec PDF #AL-204) | Aluminum Containers (§18973.1) | Cat 101: Aluminum Cans | Cat B-01: Aluminum Rigid | Green |
CFG-BEV-12OZ-01 | Shrink sleeve | PETG, printed film | 1.15 g | Tier 4 (Calibrated scale) | Plastic Film / Wrap (§18973.4) | Cat 204: Plastic Film | Cat C-04: Other Plastic Film | Amber |
CFG-BEV-12OZ-01 | 4-pack carrier clip | HDPE, rigid post-consumer | 9.80 g | Tier 2 (CAD drawing #HD-08) | Rigid HDPE (§18973.2) | Cat 202: Rigid HDPE | Cat C-02: Rigid HDPE | Green |
CFG-SNK-POUCH-02 | Stand-up pouch | Multi-material laminate | 6.40 g | Tier 5 (PO inference) | Multi-Material Flexible (§18973.5) | Cat 209: Multi-Layer Film | Cat C-09: Laminates | Red (Assigned: Supplier) |
The evidence hierarchy
To ensure your workpapers hold up under scrutiny, we grade the source evidence behind every component weight and material attribute:
- Tier 1: Current supplier specification or signed declaration: Directly tied to the specific part number and revision date.
- Tier 2: Engineering CAD drawing or technical BOM: Documenting verified component dimensions and material density.
- Tier 3: Client ERP or PLM record: Maintained with an identified operational owner and documented change date.
- Tier 4: Calibrated physical measurement: Conducted using a digital scale with a documented sampling protocol across multiple production units.
- Tier 5: Commercial invoice or purchase order inference: Unit mass derived from shipping manifests or case tare weights.
- Tier 6: Visual inspection or resin code inference: Requires documented review and technical rationale.
- Tier 7: Undocumented assumption: Flagged as high-risk and restricted from final state reporting without explicit client counsel approval.
Green: Direct documentary evidence (Tiers 1–3). Fully verified for audit defense.
Amber: Documented measurement or commercial inference (Tiers 4–5). Requires internal operational review.
Red: Unresolved or undocumented items (Tiers 6–7). Red items are flagged in the open issues register and require formal client or counsel sign-off before submission.
Dual reconciliations
We perform two independent mathematical reconciliations before finalizing any reporting workbook:
- Mass reconciliation: Total units shipped multiplied by individual component tare weights must tie out to aggregate category totals. Any discrepancy is investigated and resolved before delivery.
- Commercial reconciliation: State supply totals are cross-checked against 3PL warehouse fulfillment records, regional sales data, returns logs, and packaging purchase orders to ensure complete reporting.
Fee estimates come from published schedules, not PRO invoices. Producer status and exemptions go to your counsel. No filing without your written approval.
Fee estimate labels & schedule provenance
Because state fee rules evolve, we clearly label the regulatory status of every calculation:
Current-schedule
Calculated directly against approved, in-force state fee schedules (such as active Oregon RMA and Colorado dues schedules).
Illustrative
Preliminary ranges based on draft program proposals (such as California 2027 planning numbers prior to final plan approval).
Scenario
Comparative modeling evaluating prospective packaging redesigns or material substitutions.
Unavailable
Used when an agency has not yet published rates or when underlying packaging data is insufficient for a defensible calculation.
Every calculation workbook records the jurisdiction, data reporting year, program year, schedule publication date, and retrieval date. We never edit rates in place; all adjustments generate a version-controlled record with sources and reviewer initials attached.
Worked examples from the notes
How the method reads in practice: anatomy of a filing-ready package,what to ask packaging suppliers, andthe reporting calendar, with confidence levels. Scope edge cases live separately: tonnage tests,producer identity, andSB 343 labeling status.