Extended Producer Responsibility in the USA: What’s Next?
Extended Producer Responsibility (EPR), is a policy approach that places full responsibility for a product’s life cycle on the producer. Based on the “polluter pays principle”, EPR encourages producers to design more sustainable products, increase recycling rates, and minimize waste. To meet EPR requirements, authorities expect producers of covered materials and products to join or form a Producer Responsibility Organization (PRO). The PRO handles all EPR obligations, such as funding of the EPR system and managing the collection, sorting, and recycling of covered products.
Currently, EPR laws already cover a range of products across 33 US states, including batteries, electronics, paint, pharmaceuticals, and more. Many individual and collective PROs are already operating to oversee these EPR systems.
Emerging EPR Law: packaging, paper products and textiles
At least 18 states are now developing or implementing EPR laws focused on packaging, paper products and textiles. Producers with relevant products in these states should monitor progress closely and begin compliance preparations. Below is an overview of the current landscape for each category.
Packaging and paper products:
| State | Law | Scope | PRO | Deadlines |
| Maine | An Act To Support and Improve Municipal Recycling Programs and Save Taxpayer Money (2021) | Consumer packaging | TBD | September 2025: PRO candidates to submit application May 2026: Producers to register with approved PRO, report first data and pay fees |
| Oregon | Plastic Pollution and Recycling Modernization Act (2021) | Packaging, food service ware, and printing and writing paper | CAA (Circular Action Alliance) | April 30, 2025: Producers to register with PRO and submit report for 2024 data July 1, 20205: Fee obligations to start |
| California | Plastic Pollution Prevention and Packaging Producer Responsibility Act (2022) | Single-use packaging and single-use plastic food service ware | CAA (Circular Action Alliance) | September 5, 2025: Producers to register with PRO November 15, 2025: Producers to submit report to PRO January 1, 2027: Fee obligations to start |
| Colorado | Producer Responsibility Program For Recycling (2022) | Packaging and paper products | CAA (Circular Action Alliance) | July 31, 2025: Producers to register with PRO and submit report January 1, 2026: Fee obligations to start |
| Minnesota | Packaging Waste and Cost Reduction Act (2024) | Packaging and packaging components, food packaging, and paper products | CAA (Circular Action Alliance) | July 1, 2025: Producers to register with PRO February 1, 2029: Fee obligations to start |
| Maryland | An Act Concerning Environment - Packaging and Paper Products (2025) | Packaging and paper products | CAA (Circular Action Alliance) | July 1, 2029: Tentative date for first producer reporting to PRO |
| Washington | An Act Relating to Improving Washington's Solid Waste Management Outcomes (2025) | Packaging | TBD | January 1, 2026: PRO to be appointed July 1, 2026: Producers to register with PRO |
| Hawaii | Relating To The Environment / Relating To Waste Management (2023) | Packaging materials and paper products | TBD | EPR program needs assessment |
| Rhode Island | The Statewide Implementation Analysis 8 for a Beverage Container Redemption, Packaging, and Recycling Plan (2025) | Packaging materials, paper products and beverage containers | TBD | EPR program needs assessment |
| Connecticut | An Act Concerning The Management Of Solid Waste In The State | Consumer packaging | TBD | EPR program needs assessment Proposed bill |
| Nebraska | A bill for an act related to solid waste/Extended Producer Responsibility Data Collection Act (2025) | packaging and paper products | TBD | Proposed bill |
| Illinois | Extended Producer Responsibility and Recycling Refund Act (2025) | packaging | TBD | Proposed bill |
| Massachusetts | An Act to save recycling costs in the commonwealth (2024) | packaging material and paper products | Proposed bill | |
| New Jersey | Packaging Product Stewardship Act (2024) | packaging products | Proposed bill | |
| New York | Packaging Reduction and Recycling Infrastructure Act (2025) | packaging materials and products | Proposed bill | |
| North Carolina | An act to establish extended producer responsibility for certain producers of packaging materials, ban certain toxic substances in packaging materials, and ban intentionally added pfas in covered products (2025) | packaging materials | Proposed bill | |
| Tennessee | Tennessee Waste Reduction and Recycling Act (2025) HB0550 and SB573 | packaging materials | Proposed bill |
Textiles:
| State | Law | Scope | PRO | Deadlines |
| California | Responsible Textile Recovery Act of 2024 | Apparel and textile articles | TBD | January 1, 2026: Creation of PRO July 1, 2026: Producers to register with PRO July 1, 2023: Full compliance |
| New York | Extended Producer Responsibility for Textiles (2025) | Apparel, textile, textile articles | TBD | Proposed bill |
Status in August 2025
How producers can prepare
To navigate these evolving EPR requirements effectively, producers should take proactive steps:
Assess coverage: check if your products or materials are covered under the law. Note that exemptions for certain products or materials do apply.
Confirm producer status: Verify if your business qualifies as a "producer" under the relevant state definitions. Common exemptions include thresholds for annual sales, revenue, or the volume of covered products introduced to the market.
Track legislative progress: Stay informed about proposed bills and updates to enacted laws, as timelines and requirements can shift.
Engage with PROs: Get in touch with approved PRO to ensure you register on time, understand membership requirements, reporting obligations and fees.
These preparations can help minimize compliance risks and support broader sustainability goals, such as reducing landfill waste and promoting circular economies.
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