How to prepare and comply with state EPR laws

Complying with Extended Producer Responsibility (EPR) laws isn’t a choice; it’s a requirement in order to sell items into applicable states. So, as EPR advances, staying current with state laws and requirements has become table stakes.

In this article, our objective is to help you understand:

1. The basic compliance requirements of EPR
2. What information and data needs to be collected for reporting
3. What resources are available to support compliance efforts.
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What are the basic EPR requirements?

Let’s start with a high-level overview of the three basic requirements that exist across all state EPR laws to this point.

1. Register for each EPR program, typically with the Producer Responsibility Organization (PRO) representing the state
2. Prepare and submit your producer report(s)
3. Submit payment for any invoiced dues or fees
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Who registers for EPR programs?

Only businesses deemed as “producers” must register in states where EPR laws have passed.

Where it gets complicated is that each state has its own “producer” definition, so it’s imperative that you familiarize yourself with each state’s definition of a producer to understand how you should comply.

Determining whether to report as a producer is an assessment that needs to be made by your business. If your business has questions or concerns about where your business falls, we suggest seeking legal advice or working with an attorney.

How do producers register for EPR?

States that have laid out their regulatory requirements have either selected a Producer Responsibility Organization (PRO) or Stewardship Organization (SO) that will act to fund and manage the state’s EPR program.

The Circular Action Alliance (CAA) is a great reference point for understanding where and who to register with for each of the seven states that have passed EPR legislation as of February 2026.

What is a producer report?

Producer reports detail the amount of covered material supplied into states in which EPR laws have been passed.

The report is a critical input to help determine and set EPR fees or dues that producers must pay. These are prepared by businesses deemed as “producers” in applicable states and submitted to the designated PRO or SO.

What information is needed to complete a report?

In a nutshell, producers must know their packaging and what states their products and packaging are being sold into.

The first step is to determine what the applicable state producer's obligations are. This means having an understanding of what materials must be reported on, what categories they fall under, and what producers are responsible for.

From there, basic packaging material details must be captured. This includes the material type, per unit weight, and total quantity sold into the state(s).

How do we get the information needed for reporting?

1. Get organized internally. Develop a list of tasks and responsibilities that need to be executed and assign roles to your team. This will serve as a great exercise to see who and where there is bandwidth to take on the additional workload and/or help your business come to terms with a need to enlist outside support and additional resources.
2. Consider 3rd party tools, data analytics companies or collaborative partners. Several software platforms are available to help organizations manage EPR compliance efficiently. These tools typically offer features like automated data collection, multi-country regulation tracking, reporting, and supplier collaboration.
3. Leverage your packaging supplier to conduct a packaging audit. Work with your packaging supplier to retrieve basic product information (dimensions, weight, etc.) and assist with product categorization (containers, cups, trays, tubs, jugs, etc.). Packaging suppliers should be willing and able to help support producers when it comes to EPR compliance.
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How can we better prepare for future reporting?

1. Implement a data tracking system for future reporting. By implementing a system for tracking packaging usage, material composition, weight, and related costs, producers will be able to both improve visibility to accurate data and retrieve data needed for reporting much faster.
2. Stay updated with legislation. Regulatory landscapes are constantly evolving, so brands must stay vigilant. This can involve setting up state-specific monitoring systems or registering with Producer Responsibility Organizations (PROs) to ensure adherence to multifaceted regulatory landscapes. Other ways include subscriptions to industry newsletters, attending relevant webinars, and participating in industry associations to remain informed about new EPR developments.
3. Invest in training. Ensure that your internal teams—from product design and procurement to compliance and marketing—are well-versed with EPR implications and can make informed decisions regarding sustainable packaging practices. This will go a long way towards not only compliance, but mitigation of fees in the future.
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How do we pay EPR fees?

Typically, the designated PRO or SO manages the payment and collection process for EPR programs. Registered producers should be notified and sent an invoice for fees or dues owed to the state by the managing program where payment can then be made.

Conclusion

For producers operating in states with packaging EPR laws, success hinges on understanding the regulatory landscape, implementing robust compliance strategies, and leveraging the right tools and services.

Engage early with PROs and utilize their guidance on registration, reporting, and fee calculations.

At the end of the day, collaboration is key, and embracing this pivotal moment will help you confidently navigate the evolving world of EPR.

This article is part of Amcor’s ongoing efforts to support our customer base by simplifying the conversation on EPR into bite-sized content. If this has sparked questions or even made you wonder how EPR impacts your packaging, then please reach out by filling out the form below and a member of our team will get you connected with one of our expert packaging consultants.