EPR Is Here. Now What? What the Paper Supply Chain Needs to Know

Extended Producer Responsibility, or EPR, used to feel like something happening somewhere else — in Europe, in plastics, in policy conversations far removed from day-to-day business. That’s no longer the case.

With multiple states now implementing packaging EPR laws, including some that explicitly cover paper and printed paper, the conversation has moved from theory to invoices, reporting deadlines, and compliance questions. For companies across the paper supply chain, the biggest risk right now isn’t disagreement. It’s not knowing you’re affected at all.

To help clarify what EPR actually means for the industry, Sylvamo recently spoke with NPTA about how these programs work, where companies are getting caught off guard, and why awareness across the value chain matters more than ever.

What EPR Actually Is and Why It’s Expanding

EPR isn’t brand new. It’s simply expanding into new territory.

“We like to talk about EPR as an environmental policy that has been around for quite some time,” said Laura Pickard, director of government relations at Sylvamo. “We’ve seen it in the United States for many years for hard-to-recycle items like mattresses, batteries, paint, that sort of thing. It’s also been used in Europe and Canada for packaging and sometimes paper, and now we’ve seen it grow in the United States in recent years as well.”

Under these laws, a producer responsibility organization, or PRO, is established to administer the program, conduct needs assessments, set budgets, and collect fees from designated “producers.” In the United States, for packaging, that role currently belongs to Circular Action Alliance.

What has changed is scope.

In several states, EPR programs now extend beyond packaging to include certain paper products or printed paper. That means items like copy paper, envelopes, or direct mail may fall under the rules, depending on how a state defines “covered material.”

“It’s very important to look at the exact state legislation and regulations to know who the producer is, which means who’s going to be responsible for paying fees, and what products are included,” Pickard said. “Is it just packaging, or is it paper also?”

There is no single answer. Each state defines it differently.

The Challenge of a State-by-State Patchwork

In the United States, EPR for packaging and paper operates on a state-by-state basis, which can complicate things.

“All of the state regulations vary a lot. That is a complicating factor,” Pickard said. “It makes it hard to comply. It means you need to have legal counsel, and you need to read everything closely.”

Oregon and Colorado are already active. California and others are moving forward. Some states include paper. Others do not. Definitions of “producer” shift. Exemptions differ.

For companies shipping into multiple states, this means tracking obligations in each jurisdiction, reviewing definitions carefully, and coordinating internally to avoid missteps.

And the cost implications are real.

“In Oregon, where paper is included, fees jumped up with very little notice,” Pickard said. “They came out with draft fees that we were using to try to budget. Once producers reported their data, they realized that a lot of the folks who should be paying on paper brands did not register and report. That meant, at the very last minute, they had to increase the fees on paper for those of us who had been responsible in registering and paying.”

That situation exposed what many in the industry now call the “free rider” problem, companies unaware of their obligations inadvertently shifting costs onto those who did comply.

“When companies aren’t aware that they should be responsible for fees, it raises costs for the rest of us,” Pickard said.

There is also the risk of double payment.

“We want to make sure it’s very clear who is obligated for what paper,” she said. “So we’re only paying once and not double counting.”

From Policy to Practice: What Compliance Actually Looks Like

For manufacturers and brand owners who fall under EPR requirements, the work goes beyond registration.

Data tracking at the SKU level, packaging weight calculations, state-specific reporting categories, and annual fee updates all factor into compliance. Many companies are assembling cross-functional teams that include legal, sustainability, finance, sales, and IT to manage the process.

Registration alone does not complete compliance. Reporting and fee payments are ongoing responsibilities, and penalties for noncompliance can be significant. EPR is not a one-time form. It is a new operational consideration.

Why Sylvamo Stepped In

As EPR programs moved from proposal to implementation, Sylvamo began hearing the same question repeatedly: Who is actually responsible?

“As EPR shifted from concept to compliance deadlines, customers and channel partners began asking who was supposed to comply with these programs and what to report on,” said Gerry Klug, commercial consultant at Sylvamo. “We wanted to help where we could.”

Sylvamo’s response has focused on education. The company developed plain-language resources for customers, hosted webinars, and trained sales teams so conversations in the field reflect the most current public information available.

“We run webinars that are essentially educational platforms for our customers, our customers’ customers, and so on down the line,” Klug said. “We’re not trying to move anybody in one direction or the other. We’re just trying to make sure people are aware of the facts, what they need to be prepared for, and what the implications will be.”

That education extends internally as well.

“The better educated our teams are, the better chance they’re going to have of providing the proper and most current information when they’re talking to customers,” Klug said. “The better educated our customers are, the better chance they’re going to have of navigating this as well as they can.”

The Takeaway: Awareness Beats Surprise

With new states introducing legislation and litigation unfolding in others, the details around EPR will continue to shift. That makes monitoring state guidance important, particularly for companies shipping branded paper products across state lines.

It also makes communication across the supply chain even more important.

Distributors, wholesalers, and brand owners should be talking to one another about who is reporting and paying to avoid surprises or duplicate fees. Legal review is not optional. Assumptions, especially the idea that EPR applies only to plastics, can be costly.

There is one point of relative clarity. Fiber-based materials are generally viewed more favorably under recyclability criteria than difficult-to-recycle plastics or multi-material laminates, provided they meet each state’s standards.

For NPTA members, the goal isn’t to master every detail overnight. It’s to understand where EPR may touch your business — and to start the right conversations now.

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This feature is part of NPTA’s broader EPR coverage, with an additional industry perspective to follow.