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EPR Laws Are Here: What Extended Producer Responsibility Means for Manufacturers Who Make Plastic Parts

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For years, Extended Producer Responsibility was something European companies dealt with. That changed fast. Seven U.S. states now have EPR packaging laws on the books, fee obligations are already live in some states, and the financial and operational pressure on manufacturers is real in 2026. Here is what you need to understand.

Extended Producer Responsibility, EPR for short, is a policy framework that shifts the financial and operational cost of managing packaging waste away from local governments and onto the companies that manufacture, distribute, or sell packaged products. In plain terms: if your company sells products with plastic packaging, several U.S. states now require you to register with a Producer Responsibility Organization, report your packaging data, and pay fees based on the volume and recyclability of that packaging.
This is no longer a future concern. Oregon launched its program in July 2025. Colorado’s data reporting deadlines have already passed. California, Maine, Minnesota, Maryland, and Washington have all enacted programs at various implementation stages. More states are in the legislation pipeline as of 2026.

Which States Have Active or Enacted Programs Right Now

Oregon

ACTIVE
Launched July 2025. Producer fee obligations are live. Statewide recycling goals: 25% of plastic packaging by 2028, 50% by 2040.

Colorado

ACTIVE
Registration and reporting completed. Next producer supply reports using 2025 data due May 31, 2026. Fee invoices issued in two installments.

California

ENROLLED
Producer registration open. Next supply reports using 2025 data due May 2026. Fee obligations start January 2027.

7

U.S. states with enacted EPR packaging laws as of mid-2026, with more in the legislative pipeline

Hogan Lovells / H2 Compliance, 2026
May 2026

Reporting deadline for 2025 packaging supply data in Oregon, Colorado, California, and Maine simultaneously

Compliance and Risks, 2026
Every Function

EPR affects product development, sourcing, quality, distribution, sales, marketing, and finance, per legal analysis

Hogan Lovells, 2026
Maine

Enacted 2021. Producers expected to register and report 2025 data by May 31, 2026. Program continues to develop.

Maryland

Signed into law May 2025. Multiple PROs allowed. Implementation continuing through 2026-2027.

Minnesota & Washington

Both enacted. Minnesota PRO appointed February 2025. Washington implementation ongoing. Fee timelines developing.

What This Actually Changes for a Manufacturer

The direct compliance obligation, registration and fee payment, is one part of the picture. The longer-term business impact is more significant. EPR programs are designed to create financial incentives for packaging that is easier to recycle. Materials and formats that are harder to process carry higher fees; packaging that meets recycled content thresholds and is easily recyclable can qualify for lower fee rates, depending on the program structure.
This means packaging design decisions that used to be purely about cost and aesthetics now have a measurable regulatory cost attached. A manufacturer choosing between two packaging formats in a state with an active EPR program is effectively choosing between two different fee obligations going forward.

The Connection to Your Recycling and Regrind Operation

Here is where EPR intersects directly with equipment decisions. One of the most effective ways to reduce EPR fee exposure is to demonstrate and document that your post-industrial plastic scrap is being recaptured and recycled rather than landfilled. Clean, well-managed regrind programs are increasingly part of how manufacturers document their compliance posture and, in some frameworks, qualify for lower fee tiers.
Beyond the regulatory side: EPR laws are pushing demand for recycled content upward, which is making quality regrind more valuable as a raw material input. Manufacturers who capture their runner and trim scrap cleanly and consistently are sitting on a material asset that is becoming more valuable as recycled content mandates expand.

Note on legal advice: This post is intended as a general overview of EPR developments and their operational implications. EPR compliance is a legal matter with program-specific requirements. If your company sells packaged products in states with active EPR programs, consult legal counsel familiar with the specific program rules.

Five Practical Steps for Manufacturers Navigating EPR

Step 1: Audit your scrap capture rate

How much of your post-industrial plastic scrap is being recaptured as usable regrind versus sent to landfill or sold at low value? Document this baseline now.

Step 2: Close the loop on your highest-volume presses

If you are not running beside-the-press low speed granulators on your main injection molding lines, this is the time to evaluate them. Clean regrind is a compliance asset and a cost reduction simultaneously.

Step 3: Identify your packaging materials exposure

If your company sells products with plastic packaging into states with active EPR programs, registration and reporting obligations may apply now. Review with your legal and operations teams.

Step 4: Track your recycled content usage

EPR programs are increasingly rewarding packaging that incorporates recycled content. Knowing your regrind percentages helps you document this for both compliance and customer supply chain requirements.

Step 5: Plan for broader coverage

Additional states are actively moving EPR packaging legislation in 2026. The geographic scope of these programs will expand; building your recycling infrastructure now puts you ahead of the wave rather than behind it.

The manufacturers best positioned for EPR compliance are the ones already running efficient, well-documented internal recycling programs. If your scrap capture process needs strengthening, that work pays off in multiple directions: lower input costs, better regrind quality, and a cleaner compliance story.
Parts to keep your recycling equipment running: Screens, knives, V-belts, maintenance kits, and spare components are available through Virtus Equipment Direct, our online store for size reduction equipment parts.
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