EPR Think Tank

Extended Producer Responsibility (EPR) is rapidly reshaping the regulatory and business landscape in the U.S., with packaging now at the forefront of legislative action. As more states adopt EPR frameworks, businesses must navigate evolving compliance obligations, cost structures, and shifting producer responsibilities.

• Overview of EPR programs across industries (paint, batteries, e-waste, textiles, and packaging)
• Understanding the evolution of EPR for packaging and why it’s gaining traction now
• What’s next for producers, policymakers, and the supply chain?

As states take the lead in implementing EPR laws, your business must navigate a fragmented regulatory landscape with varying requirements, deadlines, and enforcement mechanisms. We’ll take a look at key EPR frameworks in California, Oregon, Maine, Minnesota, and Colorado, that have passed some of the most comprehensive EPR legislation and their common elements.

• A deep dive into California, Oregon, Maine, Minnesota, and Colorado’s EPR laws, with a focus on:
  • Producer responsibility for funding and managing waste collection and recycling programs
  • Mandated recycled content requirements and eco-design incentives
  • Compliance timelines and enforcement mechanisms
• Several other states—Washington, Illinois, Maryland, and New York—are advancing EPR legislation
  • What sectors and materials are being targeted?
  • How will these emerging regulations impact businesses operating across multiple states?
• Despite variations in structure and enforcement, common elements in state EPR programs include:
  • Producer-funded recycling programs and material recovery targets
  • Eco-modulation fees incentivizing sustainable packaging design
  • Reporting and disclosure requirements for manufacturers
  • Compliance deadlines ranging from 2025 to 2030

Spotlight on California’s SB 54

California’s SB 54 is one of the most ambitious EPR laws in the U.S., setting strict producer obligations:

• Understanding its key requirements and producer obligations
• Reviewing CalRecycle’s evolving enforcement framework and compliance complexities

Navigating Extended Producer Responsibility (EPR) laws requires a clear understanding of producer definitions, material scope, and compliance obligations across different states.

Let’s unpack strategies for effective recordkeeping, defining covered materials, and determining producer obligations in an evolving EPR landscape.

• Assessing which internal company functions should oversee EPR compliance
• Defining the “Producer” and understanding who bears responsibility under different state laws? (Brand owners, retailers, suppliers?)
• Understanding what qualifies as covered material and what are the industry-specific exemptions
• What is a PRO? (Producer Responsibility Organization)?
  • What can be delegated to a Producer Responsibility Organization (PRO), and what remains the producer’s burden?
• Establishing your EPR compliance plan to fit current states’ laws and regulations and anticipate future ones

Hear from Circular Action Alliance in an insightful keynote address, exploring the latest guidance on extended producer responsibility (EPR).

Join us in an in-depth discussion to gain clarity on EPR fee structures, explore how eco-modulation is shaping the future of sustainable packaging, and how you can optimize compliance costs while supporting sustainability goals.

• Understanding the overall EPR fees structure and the impact on different packaging materials
• Reviewing ‘Eco-Modulation in Action’ and how EPR systems incentivize sustainable packaging and penalize hard-to-recycle materials
• Developing strategies for balancing growth targets with reduction targets, while maintaining scalability
  • Understanding the economic impacts of reduction targets

EPR packaging laws will have a significant impact on the CPG (consumer packaged goods) industry. However, the full scope of these laws will affect many industries differently.

For example, the OTC drug industry may face different challenges than the food, supplements, or cosmetics industries. With EPR reshaping packaging and sustainability strategies, our panel will share insights on navigating these changes and balancing regulatory demands with business realities.

• Highlighting unique compliance challenges across key sectors (cosmetics, food, OTC drugs, and supplements, household goods)
• Understanding the role of packaging manufacturers in designing for recyclability and meeting new sustainability requirements
• Mitigating financial and operational challenges in an evolving regulatory landscape
• Reviewing compliance approaches for mid-sized businesses

Reporting presents a complex challenge for brands, retailers, and suppliers navigating fragmented supply chains. With new reporting forms, shifting exemptions, and no real precedent, companies struggle to collect and validate data from deep within their supply chains.

• Understanding who is responsible for tracking and reporting packaging waste?
• Upstream vs. downstream data-sharing hurdles and compliance gaps
• Assessing how large retailers manage reporting across supply chains
• Leveraging technology to streamline data collection and reporting

As the U.S. continues to explore EPR frameworks for packaging, valuable insights can be drawn from international models. Let’s take a look at the regulatory landscapes of the EU and Canada, examining how global best practices can inform the U.S. approach.

• What can we learn from EU and Canada’s structures for EPR frameworks?
• Reviewing key lessons from their EPR implementation programs and their evolution
• Understanding potential compliance hurdles and how industries have adapted