Extended Producer Responsibility: What It Means for Our Industry Now
Innovation | NPTA Staff | May 02, 2025
Extended Producer Responsibility (EPR) isn't just on the horizon anymore—it's here, and it's moving fast. If you're a producer, distributor, converter, or anywhere upstream in the packaging supply chain, you're already part of the conversation—or you should be.
Right now, the key questions we hear from members fall into two buckets: "How much is this going to cost us?" and "What are the unintended consequences we need to prepare for?"
The Immediate Impact on Producers
Let's start with the impact. As of today, seven states—California, Colorado, Maine, Oregon, New Jersey, Minnesota, and Washington—have passed packaging-focused EPR laws, with more following closely behind. These laws shift recycling costs from municipalities to producers, and they come with new obligations: registration, detailed packaging data reporting, labeling requirements, and fees based on both volume and material recyclability. For many of you, these aren't just operational changes—they're budget items, contract revisions, and packaging redesigns. And if you're not directly on the hook, your customers might be, which means the pressure is coming downstream.
For example, California's SB 54 sets aggressive packaging recyclability targets and fees that will shape material choices for years to come (CalRecycle). Maine's program, launching producer reporting requirements in 2026, will reimburse municipalities directly and demand deep transparency about what gets sold into the state (Maine DEP). Colorado and Oregon are both building PRO-led (Producer Responsibility Organization) systems that will manage recycling programs on behalf of producers. All of these programs bring with them questions about compliance complexity, enforcement clarity, and cost equity across the supply chain.
"EPR is forcing real conversations around accountability, cost, and sustainability. It's not just about compliance—it's about readiness and leadership."
Where Paper Holds the Advantage
But it's not all risk. There's opportunity here, too.
If you're working with recyclable, fiber-based materials, you're already ahead. Many of these EPR programs are adopting eco-modulation fee structures, meaning packaging that is easier to recycle and costs less to recover. That puts paper and paperboard packaging at a competitive advantage compared to less sustainable formats. In other words: recyclability is about to have a dollar value.
This also presents a chance for paper professionals to shape the narrative. We've long known that paper is one of the most recycled materials in the country (AF&PA). In an EPR framework, that story matters. The more we can quantify and communicate the environmental and economic value of fiber-based packaging, the better positioned we are to guide brands toward compliant, lower-impact solutions.
What's Next for the Industry?
Beyond that, there's a broader conversation happening about packaging design, waste reduction, and the future of recycling infrastructure. EPR is just one lever in a much larger push toward circularity. The companies that adapt early will not only meet compliance expectations but become go-to partners for customers looking to future-proof their operations. We're already hearing from members who are fielding more questions from customers about sustainable material choices, recyclability claims, and supply chain transparency. This is a critical moment to reinforce the role of paper as a preferred material and to educate stakeholders on its strengths.
Navigating a Patchwork of Rules
Still, it would be a mistake to assume the rules will be clear-cut or consistent. Definitions of "recyclable," reporting thresholds, and enforcement approaches vary widely by state. New York, Maryland, and Illinois are all at different stages of developing EPR proposals, and we'll likely be managing a patchwork of requirements for years to come. For multi-state businesses, that means navigating overlapping timelines, PRO requirements, and reporting frameworks. It won't be easy, but the earlier you engage, the more prepared you'll be.
NPTA's Role Moving Forward
At NPTA, we're closely monitoring EPR implementation across the states and engaging with coalitions when possible. While we aren't setting policy, we are here to help members stay informed and ahead of the curve. We'll continue to share updates, host conversations, and offer insight as these programs evolve.
What You Can Do Today
Now's the time to review your packaging data, understand where your customers operate, and assess whether you're directly obligated under new laws. And even if you're not, it's smart business to help your customers navigate compliance and optimize their packaging. Helping a brand reduce its fee exposure by switching to fiber-based packaging isn't just good service—it's a differentiator.
EPR is real, it's here, and it's growing. Let’s be sure our industry continues leading the way with practical, sustainable solutions—and a voice at the table.
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