Extended Producer Responsibility (EPR) laws are beginning to reshape packaging and paper obligations in the U.S., following a model already common in Europe and Canada. These laws shift responsibility for recycling and waste management from consumers and governments onto the companies that place products on the market.
At their core, EPR programs require “producers” (who a “producer” is will vary by law) to:
- Register with a state-approved Producer Responsibility Organization (PRO), such as the Circular Action Alliance (CAA)
- Report the type and quantity of covered materials they sell or distribute in the state
- Pay program fees based on those materials, which fund statewide recycling and recovery systems
Obligations typically apply to products like “packaging,” “printed paper” and “food serviceware/service packaging,” although the exact scope varies by state. Small producers and nonprofits may be exempt if they fall below certain revenue or tonnage thresholds.
While requirements differ slightly, the process is similar across states: register with CAA, sign participation agreements, submit annual data reports and pay invoices once fees are assessed. For many companies, this means tracking their packaging and printed materials by weight and category for each state where EPR is active.
So far, Oregon and Colorado have programs underway, with California launching and a number of other states preparing to follow in the next few years. More states are actively considering similar legislation.
For businesses, the takeaway is clear: EPR compliance is no longer optional or a future concern, it is here now. Companies that produce or distribute packaging, printed paper or food-serviceware/service packaging into these states should confirm whether they are an obligated producer, assess exemptions and prepare to report and pay fees through CAA.