Packaging Extended Producer Responsibility (EPR), in plain English

Packaging Extended Producer Responsibility (EPR) laws require the companies that make and sell packaged products to help fund the recycling of that packaging. In the states with these laws, producers generally join a producer responsibility organization (PRO), report the packaging they supply into the state, and pay fees that fund the program.

No. Packaging Extended Producer Responsibility laws are not limited to food and beverage companies. They can apply to any company that sells packaged products destined for California, Colorado, Maine, Maryland, Minnesota, Oregon, or Washington, if that company meets the state's definition of a producer and is not exempt. Food and beverage packaging is generally included unless a specific exclusion applies. Minnesota's law names food packaging specifically, and California's SB 54 covers single-use packaging and single-use plastic food service ware. Some states exempt certain food-related packaging, such as packaging for infant formula or medical food. Whether your company is covered depends on each state's producer definition and exemptions, and exemptions vary by state.

Seven states have comprehensive packaging Extended Producer Responsibility (EPR) laws: California, Colorado, Maine, Maryland, Minnesota, Oregon and Washington. Each state runs its own program through its environmental agency, and the programs are at different stages. Circular Action Alliance is the PRO in California, Colorado, Maryland, Minnesota, Oregon and Washington. CAA chose not to bid on Maine's June 2026 request for proposals and has no role in Maine's program right now. Producers have no obligations to CAA in Maine and should follow the Maine Department of Environmental Protection for updates.

It depends on the state. Each state's Extended Producer Responsibility law sets its own order of who counts as the producer, and the brand owner is usually first in line. If you own the brand on the package, assume you may be the producer and check each state where your products are supplied, including products a co-packer makes for you. If you ship direct to consumers, you may also be the producer of the shipping box and fill. For private label or licensed brands, it depends on whose brand is on the pack and on the agreement, so check before you report.

Some are. Several packaging Extended Producer Responsibility programs exclude small or de minimis producers based on revenue or the amount of packaging supplied. In Minnesota and Maryland, for example, the definition of producer does not include a company that, in its most recent fiscal year, introduced less than one ton of covered material into the state or earned global gross revenues under $2,000,000. In Colorado, the revenue limit is adjusted for inflation each July 1, and CAA's Colorado guidance links to the current figure. Colorado also exempts producers that used less than one ton of covered material in the state in the prior year. Thresholds differ by state, so check each one.

Circular Action Alliance (CAA) is a producer responsibility organization. Circular Action Alliance is the PRO in California, Colorado, Maryland, Minnesota, Oregon and Washington. Producers in those states register with CAA and report through CAA's Producer Portal, unless they qualify for an exemption or file an individual program plan where the law allows. CAA sets fees using its fee-setting method, within each state's law, regulations and approved program plan. California's 2027 rates are preliminary and non-binding until the state approves CAA's program plan.

For packaging Extended Producer Responsibility reports, Circular Action Alliance's Reporting Policy sets May 31 as the default annual deadline for supply reports, based on the prior calendar year. If May 31 falls on a weekend or holiday, the deadline moves to the next business day. Under that policy, reports on 2026 supply are expected June 1, 2027, because May 31, 2027 is Memorial Day. CAA has not yet posted its 2027 report dates. Check each state's date with CAA. CAA does not run Maine's program, so there is no Maine report to CAA. Follow the Maine Department of Environmental Protection for updates.

In general, your packaging Extended Producer Responsibility fee is the weight of each packaging material, multiplied by a per-pound rate for its material category, for the units you supplied into each state. Every state has a different fee structure for each material, so the same package can be charged differently from one state to another. Some states then adjust fees up or down for things like recyclability, post-consumer recycled (PCR) content or problem materials. California also adds a charge for each plastic component. In Colorado, transport packaging such as shipping boxes, pallets and pallet wrap that only moves between businesses is exempt. In Washington, packaging is covered when it is supplied with the product to the consumer for personal, noncommercial use. CAA sets fees using its fee-setting method, within each state's law, regulations and approved program plan. California's 2027 rates are preliminary and non-binding until the state approves CAA's program plan.

Yes, legitimately. Start by reporting accurate weights and the right material categories instead of conservative defaults. Over time, packaging changes help most: lighter packs, switching mixed-material packs to a single material, adding recycled (PCR) content, and moving away from materials that disrupt recycling, which pay more in some states (Colorado adds 5% for them, including on PVC). Make sure you claim the exemptions you qualify for and that the right company is reporting as producer. Fee adjustments for recyclability and recycled content vary by state, and some are still being finalized, so we check each one.

For each product, list every packaging component (film, tray, label, carton, case, shipper) and its specific material, such as PET, PP, LDPE film, paperboard or corrugated, not just "plastic." Add its weight, how many units you supplied into each state, and the brands they're sold under. Spec sheets from your suppliers are best, and a few samples work when you don't have them.

Yes, with limits. Circular Action Alliance's Reporting Policy lets a producer add up to two Reporting Contacts, who do not need to be employees. A Reporting Contact can begin and edit reports but cannot submit them. The producer's own Primary Contact or Authorized Representative submits the report and attests that it is accurate and complete. Both must be employees of your company. In states where Circular Action Alliance is the PRO, we walk you through the initial setup with CAA so EPR Compliance Partners is listed as a Reporting Contact, then we handle the hard part from there: gathering your packaging data, preparing the report, and entering it in the portal for your team to review, attest to, and submit.

We prepare packaging Extended Producer Responsibility (EPR) reports for companies that sell packaged products into states with active packaging EPR programs, including food and CPG brands. We figure out where you're obligated, turn your packaging specs into reportable data, prepare your reports and estimate your fees. We make sure every package is reported accurately and in the right category, so you don't overpay. We follow Circular Action Alliance's published guidance and speak directly with CAA when guidance is unclear. With your signed approval of the final numbers, we enter your report in CAA's portal as your Reporting Contact, and your own Primary Contact or Authorized Representative reviews it, attests to it and submits it. Your company submits and attests to the report and remains legally responsible for it.