With Extended Producer Responsibility (EPR) laws for paper and packaging rolling out across multiple U.S. states, producers must navigate a new and evolving regulatory landscape. Seven states (California, Colorado, Maine, Maryland, Minnesota, Oregon, and Washington) already have lawmakers introducing or considering their own versions, as do many others.
Navigating producer obligations under these laws can be a full-time job, especially if you operate in multiple states. By partnering with a trusted Producer Responsibility Organization (PRO), producers have access to valuable resources and guidance and can keep their organizations compliant with current and upcoming EPR requirements.
Founded by producers across the food, beverage, consumer goods and retail industries, the Circular Action Alliance (CAA) works to ensure that producers comply with and harmonize EPR laws, provide best-in-class services and work with governments, businesses and communities to reduce and recycle waste.
The role of EPR
EPR laws provide many benefits to communities, organizations, and the environment.
This law helps improve recycling infrastructure, creates packaging design consistency, and increases recycling system efficiency. Goals like these can be good for business rather than just becoming another regulation.
For example, collecting valuable data on packaging to meet reporting requirements can give producers a better understanding of the composition of the packaging they supply to various markets. This allows producers to make more strategic business decisions about how to design and specify packaging for each product.
“There can be a lot of power in preparing and learning from all the data,” said Geoffrey Inc., senior vice president of producer services at Circular Action Alliance. “These insights can help companies make more environmentally conscious decisions and improve the clarity of business decisions about the packaging they supply to the market.”
CAA’s Initial Program Successes and Partnerships
“When I look back on the past year, I’m amazed at how much we’ve built and how much success we’ve had with all of our producers,” Inch said.
That success includes Launch of an effective EPR program in Oregon. CAA initially worked with a small team to assist producers in supplying the Oregon Register and preparing and submitting data to CAA. This data allowed the CAA to implement the EPR program and help producers remain compliant.
Many of those producers were completing EPR supply reports for the first time, so CAA provided webinars and other guidance to help them get their data in order and navigate the submission process. Oregon’s program also followed a successful producer reporting cycle in Colorado and preparations for a producer reporting in California in November.
Compliance is a priority
So what does producer compliance look like?
“We are focused on getting people into a low-impact rhythm for all of their obligations,” says Inch. “This starts with identifying a primary EPR contact within the producer organization who can engage with the CAA to understand the company’s registration and reporting requirements.”
For the CAA, Inch notes, “the plan is also to migrate to a consistent annual producer reporting cycle and provide producer supply reports for multiple programs on the same deadline, targeting May 31st.” By having producers submit data on the same date each year, Pro can efficiently verify supply data to ensure accuracy.
“By ensuring everyone reports data consistently, we can establish a fair and transparent system for setting EPR rates for the producers we work with,” Inch said.
Accurate reporting is a key step for producers to maintain regulatory compliance. Especially since regulators have enforcement mechanisms that can include fines or sales bans.
CAA is an important EPR partner
“We are also here to help people sort through the complexities as EPR laws vary from state to state,” Inch said. “CAA supports producers through every step of their compliance journey, providing clear guidance, reporting tools, and a manageable and efficient process for submitting all required supply data.”
Taking the guesswork out of EPR obligations across multiple programs eliminates a major stress point for producers when new laws go into effect, which is a great reason to work with the CAA. But there is another reason. As with any new law, you can make mistakes and fall out of compliance. CAA helps producers discover where they are tracking and get their organization back on track.
What if the producer is based in a state without EPR regulations? Contacting CAA is still a good idea. All producers supplying materials subject to EPR status must meet reporting and compliance requirements.
Upcoming reporting deadlines
For California’s initial reporting cycle, CAA is currently accepting submissions of 2023 supply data with a deadline of November 15, 2023. CAA provides support, guidance, and tools to help creators prepare for this data submission. If you have questions or are a producer needing support, please contact us (email protected)
