Extended Producer Responsibility (EPR) is reshaping the packaging landscape. As regulations expand across the United States, businesses must understand evolving requirements, reporting obligations and the potential impact on packaging costs.
Whether you're just beginning to prepare for compliance or looking to optimize your approach, Pregis can help you understand the implications and evaluate packaging strategies that support both sustainability and business performance.
U.S. EPR Programs
Who's Responsible?
Under EPR programs, financial responsibility falls on entities defined as “producers,” typically brand owners or companies that choose the packaging and sell the packaged product into regulated states. Producers are required to pay fees to help fund the recycling of their packaging materials.
Determine Your EPR Responsibilities
How Does EPR Work?
Producers, companies that sell packaged goods into EPR states, pay fees to the Producer Responsibility Organization (PRO). As of July 2026, the designated PRO for paper and packaging in the United States is Circular Action Alliance (CAA). The PRO collects and manages these funds, which are then used to support the collection, sorting, recycling and consumer education related to packaging materials within each state.
What Packaging Is Affected?
All packaging materials, including paper, plastic, metal and glass, are subject to EPR fees. Fees are typically assessed on a per pound basis and vary by material, reflecting the cost and complexity of recycling each packaging type.
Packaging EPR: What You Need to Know
Frequently asked questions about EPR compliance, fees, reporting and packaging optimization.
EPR programs have existed for years in other jurisdictions such as Canada and Europe. As of July 2026, Oregon, Colorado, California, Maine, Minnesota, Maryland and Washington have passed EPR bills. Other states, including Wisconsin and New Hampshire, are considering similar legislation.
The Circular Action Alliance (CAA) outlines several acceptable methodologies for reporting packaging usage. Companies may track packaging consumption through procurement or operations records, bills of materials or units sold. Reporting typically requires collaboration across the supply chain to properly track packaging weight, quantity and material composition.
If the CAA identifies a company as "delinquent," it contacts the company and the applicable state agency. Some EPR laws require the CAA to publish a public, searchable registry of registered producers and whether they are in good standing.
Yes. For example, Oregon will update its fee schedule “annually at minimum to reflect changes to producer supply tons, system operations and costs” (Oregon Program Plan, 194). Fees in other states will be reviewed at a frequency outlined in legislation. Fees may vary as recycling rates change, more producers register or producer financial obligations change under legislation.
Currently, states and municipalities fund and manage waste services. Recycling rates remain low due to factors such as outdated infrastructure, limited consumer education and hard-to-recycle packaging formats. EPR shifts the financial, and sometimes operational, responsibility for packaging waste management to producers through packaging fees. These fees help fund recycling infrastructure and education programs while encouraging more recyclable packaging formats.
Although definitions vary by state, packaging is generally considered recyclable if it can be routinely collected, sorted, processed and sold into an end market through existing recycling systems at scale. Some packaging may be technically recyclable but not practically recyclable due to infrastructure or economic limitations.
EPR fees are only one part of total cost of ownership. Packaging decisions should consider material costs, labor, throughput, warehousing, freight, product protection and brand performance alongside EPR fees. Get in touch with our team for a holistic evaluation of your packaging strategy.
Packaging Legislation We're Tracking
Regulatory requirements continue to evolve across North America and globally. Key packaging legislation we're tracking as it relates to the Pregis portfolio includes:
For the latest updates on packaging policy and regulatory developments, explore Sustainable Packaging Coalitions (SPC) Policy Roundup.
Turning Compliance Into Opportunity
As the packaging regulatory landscape evolves, compliance is just the starting point. Guided by our 4R's material strategy, we help customers navigate changing requirements while balancing performance, sustainability and long-term business value.
