Extended Producer Responsibility and Foodservice Packaging*
February 25, 2026 – What We Know and How ACR Is Responding**
The policy conversation around Extended Producer Responsibility (EPR) has shifted into real-world regulation, with laws already in place in several U.S. states and more on the way. For companies involved in foodservice packaging, the priority now is understanding how EPR affects your operation and managing compliance without disrupting pricing, service, or customer relationships.
This overview summarizes what is known today, how ACR is approaching compliance, and the critical issues foodservice packaging customers should be evaluating now.
What is EPR?
Extended Producer Responsibility (EPR) is a policy framework that shifts the financial responsibility for post-consumer packaging waste management from municipalities to producers.
In practical terms, EPR laws typically require obligated companies to:
- Register with a state approved Producer Responsibility Organization (PRO)
- Report packaging volumes by material type
- Pay eco-modulated fees based on material type and environmental performance
- Support recycling performance targets established by the state
For foodservice packaging, these requirements introduce new reporting systems, new costs, and new cross-functional coordination needs.
Where EPR Is Active in the United States
Multiple states have enacted packaging EPR laws that are in effect or moving through phased implementation, including:
- California
- Colorado
- Maine
- Maryland
- Minnesota
- Oregon
- Washington
In several of these states, the Circular Action Alliance (CAA) has been approved as the Producer Responsibility Organization (PRO). Obligated producers in those states are typically required to join CAA or another approved PRO to comply.
Each state differs in:
- Registration deadlines
- Reporting timelines
- Fee methodologies
- Covered materials
- Definitions of “producer”
While details vary by state, several elements are clear across enacted laws:
- The definition of “producer” is broad
- Registration and reporting are mandatory
- Fees are tied to material and design, typically based on:
- Total weight of packaging placed into the market
- Material type such as paper, molded fiber, plastic, or aluminum
- Recyclability and environmental attributes
- Use of post-consumer recycled content
- Multistate complexity will continue
There is no national EPR standard in the U.S. Each state program is unique. Companies operating nationally should expect ongoing administrative complexity and evolving guidance.
Canada’s EPR systems are further along and administered at the provincial level. Most provinces require obligated producers to:
- Register provincially
- Join a Producer Responsibility Organization
- Report annual packaging supply data
- Pay material-based fees
ACR’s Approach to EPR Compliance
ACR is actively engaged in monitoring and compliance where required for our business activities.
Our approach includes:
- Registering with appropriate Producer Responsibility Organizations where applicable
- Tracking evolving legislation across the United States and Canada
- Evaluating our portfolio exposure by material category
- Assessing potential fee impacts and supply chain implications
- Communicating transparently with customers about regulatory developments
Our objective is straightforward: maintain compliance where required, anticipate cost drivers, and support customers in navigating a shifting regulatory environment without unnecessary disruption.
- EPR is active and expanding
- Producer definitions vary and require legal interpretation
- Registration and reporting obligations are real
- Fees are tied to material type and design
- Multistate compliance adds complexity
- Data coordination is essential
- Cost exposure should be modeled now
EPR represents a structural shift in how packaging systems are funded and therefore cannot be treated as a one-time compliance task. It requires coordinated planning across supply chain, regulatory, and commercial teams.
By clarifying producer status, strengthening data systems, and modeling financial exposure early, organizations can adapt strategically rather than reactively.
August 12, 2025 – State-level EPR laws and regulations are reshaping packaging decisions. Here’s what’s changing, and how ACR is helping operators stay compliant and competitive.**
Extended Producer Responsibility (EPR) in the United States is a policy approach where producers are held responsible for the end-of-life management of their products and packaging. This means manufacturers, brands, and importers must fund or manage the collection, recycling, or disposal of products they introduce to the market. The goal is to reduce waste, drive circularity, and shift the financial and operational burden of waste management away from local governments and taxpayers.
In the U.S., EPR is implemented at the state level, not federally. Currently, states like California, Oregon, Colorado, and Maine have active EPR laws specifically for packaging. Others, including Washington, Maryland, and New York, are considering legislation or have pilot programs in progress. Obligated parties typically include consumer product companies and private label retailers. Why it matters: EPR is reshaping supply chains, forcing companies to rethink material use, invest in recyclability, and stay ahead of state-by-state compliance. With momentum building, especially on packaging, EPR is no longer a fringe regulatory concept, becoming a competitive and operational imperative.
At ACR, we proactively partner with legal and regulatory experts to monitor emerging EPR legislation and ensure our strategy remains future proof. This collaboration positions us ahead of the curve, enabling us to anticipate regulatory shifts, adapt quickly, and guide our customers through compliance with confidence.
*This content is provided for general informational purposes only and does not constitute legal advice. Companies should consult qualified legal counsel to assess their specific obligations.
**DEVELOPING STORY: Further updates on Extended Producer Responsibility (EPR) will be shared as state-level legislative developments continue to unfold.
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