Frequently asked questions
Short answers with the boundary stated plainly. Anything fact-specific needs your data and, where law is involved, your counsel.
Are you a law firm? Is this legal advice?
No. Producer Ledger is a solo data/compliance consultancy, not a law firm, and nothing here is legal advice. Producer identity, exemptions, assignment, enforcement, and whether you may continue selling go to your qualified counsel. Every engagement records who owns each legal determination — you or your counsel — in writing.
Which states do you cover?
Initial operating focus is California, Oregon, and Colorado packaging. Maine, Minnesota, Maryland, and Washington are monitored for future-year work — their programs are phased (Minnesota cost coverage starts 2029; Maryland plan due 2028; Washington plan due 2028; Maine has no contracted stewardship organization yet).
We sell in California. What applies on January 1, 2027?
Under PRC §42051(b), on plan approval or January 1, 2027, whichever is sooner, a covered producer generally may not sell covered material unless approved to participate in an approved PRO plan or through an approved individual pathway, subject to exemption processes. Whether that captures your entity is fact-specific — confirm with counsel and CAA/CalRecycle. California also invoiced a separate 2026 early fee, and the full 2027 category schedule was still provisional at last review (expected with the October 13, 2026 plan submission).
What does the 2026 vs 2027 California fee distinction mean for us?
They are separate inputs: the 2026 early fee was invoiced under its own schedule; 2027 planning ranges built before the final schedule are illustrative estimates, not current-schedule estimates and not quotes from the state or PRO. This practice keeps them in separate calculation runs with separate schedule versions.
Does "under a ton" exempt us?
There is no single ton test. California has no general ton threshold (it runs a sub-$1M California-sales small-producer path with a process). Oregon uses 1 metric ton; Colorado uses 1 dry short ton (2,000 lb) — different units. Other states differ again in revenue basis and aggregation. Every engagement runs a state-specific screen with evidence.
Can a contract make someone else the producer?
Sometimes, with formalities. Maine, Minnesota, and Washington offer an express path: signed assignment plus assignee PRO participation plus written certification. Maryland is worded differently. California, Colorado, and Oregon have no equivalent express override — a private cost-sharing contract does not change who the statute treats as producer. Ambiguous cases go to counsel.
What do you need from us to start?
A 20-minute fit check first: legal entities and brands, states supplied, revenue/tonnage bands, current registrations or reports, unique packaging configuration count (not just SKUs), and where specs live — a redacted example is ideal. Do not send full archives, credentials, or confidential pricing in the first email.
What does a diagnostic cost?
Fixed-fee, quoted after the fit check once the configuration count is known. Bounded diagnostic covers up to 25 configurations; a filing-ready pilot covers up to 50 configurations across up to 3 states. No hourly meter and no percentage-of-savings pricing.
Do you guarantee fee savings or acceptance of our filing?
No. No guaranteed exemption, acceptance, fee amount, savings, or enforcement outcome. Fee outputs are versioned estimates from named published schedules, not agency or PRO invoices. Savings are only ever stated against a real, comparable, approved baseline.
How is our data handled?
Source files are retained per the engagement agreement and deleted from temporary copies on close. No raw client data goes into an AI service unless you have approved that vendor and its retention and training terms. No data is sold; do-not-contact requests are honored promptly. See the privacy notice.
Do you file on our behalf?
Draft portal workbooks are prepared and filings supported only where the portal permits an authorized agent — and never without your explicit written approval of the final data, assumptions, and producer identity. Submission receipts and uploads are archived.
How do your estimates stay current when schedules change?
Rates are never edited in place. Every schedule version is retained with source, publication and retrieval dates, and status (draft, illustrative, submitted, approved, in-force, enjoined, superseded). A change creates a new version, impacted calculations are re-run, and a revision note is issued.