PROTOCOL 066 · EPR Compliance Reporting · CircularOS
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Protocol 066 · New · Sealed 01 May 2026 · CircularOS

EPR Compliance
Reporting Protocol.

What gets reported, to whom, on what schedule, in what format, and what happens when the regulator contests a figure. Extended Producer Responsibility compliance reporting is not a once-a-year admin task — it is a continuous chain of custody from tonne collected to dPRN issued to EPR obligation discharged. This protocol governs every step of that chain.

Protocol 066 · New Quarterly + Annual Truth Ledger Source Regulator Dispute Path CVCaaS Integrated
Reporting Schedule
Monthly
Internal ledger reconciliation — tonnes collected, dPRNs minted, meals funded
Internal · Sovereign only
Quarterly
Client EPR obligation discharge report — tonnes processed on their behalf, PRN/dPRN references, chain of custody certificates
External · Client-facing
Annual
Full EPR compliance return — submitted to Environment Agency or devolved equivalent, covering the full calendar year's verified tonnage
External · Regulatory
On-Demand
Ad hoc compliance certificate issued to any client or partner upon request — generated from Truth Ledger in <24 hours
External · Client-facing
Section 01 · Data
What Gets Reported

All reporting is sourced exclusively from the Truth Ledger. No reporting is based on estimates, declarations alone, or third-party summaries unless supported by a Truth Ledger entry.

Data FieldSourceIncluded In
Total tonnes collectedWeight tickets + Truth LedgerMonthly · Quarterly · Annual
Material type breakdownGrade classification at verificationQuarterly · Annual
dPRN batch referencesMinting logQuarterly · Annual · On-demand
PRN registration numbersEA registrationAnnual · On-demand
Collection site addressesCRM + GPS stampsAnnual · On-demand
Processor detailsProcessor registryQuarterly · Annual
Beneficiary organisations (meals)VMR LedgerAnnual · On-demand (impact)
Client EPR obligation referenceClient CRM recordQuarterly · On-demand
Section 02 · Recipients
Who Receives What
  • The Environment Agency (or devolved body): Annual EPR return, submitted via the Producer Responsibility Obligations Packaging Waste Regulations portal. Deadline: 28 February annually for the prior year.
  • Clients (Producers): Quarterly obligation discharge report — confirms what percentage of their EPR packaging obligation has been met through CircularOS-verified tonnage. Sent by email with PDF certificate and raw data CSV.
  • Processors (50/50 Nodes): Monthly internal reconciliation — their share of tonnes processed, dPRN proceeds due, Covenant deduction confirmed.
  • Sovereign internal: Monthly ledger reconciliation — full pipeline view, gap analysis, projection for next quarter.
  • On-demand (any party): Single-tonne or single-batch certificate — generated from Truth Ledger within 24 hours of request. Used for audits, tenders, planning applications.
Section 03 · Format
Report Formats & Delivery
  • PDF Certificate: Branded CircularOS compliance certificate — client name, reporting period, total tonnes, dPRN references, Sovereign signature. Suitable for tendering, planning, and regulatory submission.
  • CSV Data Export: Raw data from Truth Ledger — date, weight, material type, collector, processor, dPRN batch, PRN reference. Machine-readable for client ERP systems.
  • API Feed (Live Ledger): Real-time verified tonnage data available via the Live Ledger API for clients with portal integration. Updated within 24h of each verified collection.
  • Regulatory Return Format: Environment Agency format — NPWD (National Packaging Waste Database) submission format, completed from Truth Ledger data.
Section 04 · Dispute
When the Regulator Contests a Figure
  • Regulator queries a reported tonne: Pull the full Truth Ledger entry for that batch — weight ticket reference, photograph URL, processor ID, date/time, minting reference. Respond within 10 working days.
  • Regulator requests site inspection: Facilitate within 14 days. Ensure all physical records (weight tickets, labels) are accessible. Digital records (Truth Ledger, Evidence Vault) are provided as a secure data export.
  • Regulator contests a total figure: Full audit trail submitted — all monthly reconciliations, all dPRN batch records, all client reports for the contested period. If discrepancy found in our records, the Dispute Resolution Protocol (Protocol 062) is triggered internally to trace the source.
  • Penalty notice received: Escalated immediately to Sovereign. Red Team engaged. External legal counsel notified. No admission of liability without Sovereign sign-off.
⚠️ Never submit an amended return without first reconciling the discrepancy through the Truth Ledger. Amending a return based on a regulator's assertion alone — without your own audit — creates a false record. Protocol 062 (Dispute) applies to regulatory disputes as well as commercial ones.
Regulatory Dispute Closed When
Regulator confirms acceptance of the submitted data or amended return. Written confirmation filed. Truth Ledger entry updated with regulatory reference number.
Section 05 · Automation
CVCaaS Integration
  • CVCaaS (Circularity Verified Compliance as a Service) automates the quarterly client report generation — pulling from Truth Ledger and producing the PDF certificate and CSV export without manual compilation
  • 18 checkpoints in the CVCaaS verification pipeline feed directly into this protocol — each checkpoint generates a reportable data point
  • EPR Shield feature within CVCaaS provides clients with a real-time compliance dashboard — they can see their obligation met percentage without waiting for the quarterly report
  • Annual return generation: CVCaaS compiles the NPWD-format submission from the full year's Truth Ledger data — reviewed by Sovereign before submission, never submitted automatically
⚙️ Sovereign Jobs · Roles This Protocol Generates
EPR Reporting Officer
Compile and submit EPR compliance reports to the Environment Agency on the required schedule, with SHA-256 sealed submission records.
Compliance Data Analyst
Aggregate and verify all tonnage, material type, and chain-of-custody data required for EPR compliance submissions.
Regulatory Submission Lead
Own the relationship with the regulator, manage submission timelines, and handle all queries arising from EPR compliance reports.
3 sovereign jobs · View all jobs →
Protocol Seal · EPR Compliance Reporting · 066 · 01 May 2026
Extended Producer Responsibility is the commercial reason most of the clients in this system are here. They have an EPR obligation. We discharge it. Protocol 066 is the sovereign guarantee that when a regulator asks how that obligation was discharged, we have the answer in the Truth Ledger, in the right format, traceable to the exact tonne, the exact date, the exact collection site, and the exact dPRN. That is what makes this system worth £450 a tonne. Not the plastic. The proof.
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