Emerger Strategies: Sustainability Consulting

EPR for Packaging Laws (and Fees) Take Effect in 2025. Is Your Brand Ready?

Beach cleanup. Mogadishu, Somalia by United Nations Assistance Mission in Somalia is licensed under CC-CC0 1.0

Key Deadlines & How Emerger Strategies Can Help

Extended Producer Responsibility (EPR) laws are reshaping the packaging landscape in the United States, putting more responsibility on brands to manage the lifecycle of their products and packaging. These laws aim to reduce waste and environmental impact by requiring producers (brands) to finance the collection, recycling, and disposal of packaging materials. As a result, brands selling in states with EPR laws need to adapt quickly to stay compliant.

Here’s a look at key EPR packaging laws and deadlines by state, along with how Emerger Strategies can help your business prepare:

Key Deadlines by State

  1. California: The California Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54) requires producers to ensure that 65% of all single-use packaging is recyclable or compostable by 2032. Reporting requirements for compliance begin January 1, 2026.
  2. Colorado: Colorado’s Producer Responsibility Program for Recycling mandates producers to participate in a statewide stewardship organization starting July 1, 2025. Companies will need to report their packaging volumes and pay associated fees.
  3. Maine: Maine’s LD 1541 requires producers to register and report packaging material use by January 1, 2026, with fee schedules tied to recyclability and environmental impact.
  4. Oregon: Oregon’s Plastic Pollution and Recycling Modernization Act requires producers to join a Producer Responsibility Organization (PRO) by July 1, 2025, to finance waste management systems.

What Your Brand Needs to Do

  1. Register with a PRO (Circular Action Alliance (CAA)): Circular Action Alliance (CAA) is a U.S. Producer Responsibility Organization (PRO) dedicated to implementing effective Extended Producer Responsibility (EPR) laws for paper and packaging.
  2. Report Packaging Data: Producers (brands) will need to report packaging data by type and weight that are sold in or into the State.
  3. Pay Fees: Each State with EPR for Packaging will have different per pound fees that will incentivize (smaller fees) more sustainable packaging options.

For frame of reference, here are some estimated producer (brand) EPR fees on some common grocery items based upon the recent Circular Action Alliance 3rd and final program plan released 12/6/24. Please keep in mind Oregon has a shared model. Colorado fees could look very different. Estimated fees are in red and represent low to high estimates per package. Average 1-2% of retail price.

Image Credit: Gary S. Cohen

How Emerger Strategies Can Help

Compliance with EPR laws can be complex, especially for brands navigating multiple state requirements. That’s where Emerger Strategies comes in. We simplify sustainability for businesses and help you make the business case for compliance. Here’s how we can support you:

  1. Packaging Audits & Scorecards: We measure & evaluate your current packaging materials and their recyclability, and identify areas for improvement.
  2. Estimating EPR Fees: We estimate the fees for different packaging materials for budgeting purposes, and create tailored plans to ensure your brand meets state-specific EPR requirements while aligning with your sustainability goals.
  3. Retailer Readiness: Big-box retailers like Walmart and Target expect their suppliers to comply with EPR and sustainability standards, in addition to having packaging and zero waste goals of their own. Emerger Strategies ensures your brand meets these expectations to remain a trusted partner.

Why Act Now?

Non-compliance with EPR laws can lead to fines, damaged reputations, and even restricted access to key markets. Acting proactively can help your brand:

At Emerger Strategies, we’re here to simplify compliance, empower your team with the tools you need, and position your brand as a sustainability leader in the outdoor and fishing industries. Check out our Sustainability Consulting Services or Contact us today to learn more about how we can help your business thrive in an EPR-regulated world.

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