Data story: key signals in Extended Producer Responsibility (EPR)

In 2024, the global landscape of Extended Producer Responsibility underwent a seismic shift: approximately 400 EPR policies now operate across 63 countries, with the EPR compliance software market reaching $1.2 billion and projected to quadruple to $4.8 billion by 2033 at a compound annual growth rate of 16.7% (OECD, 2024; Marketintelo, 2024). In the United States alone, seven states enacted packaging EPR laws by year-end 2024, with Oregon becoming the first to operationalize fee collection in July 2025. This regulatory acceleration signals a fundamental restructuring of how producers, from consumer packaged goods giants to e-commerce retailers, will finance and manage end-of-life product stewardship. For sustainability professionals, investors, and policymakers, understanding the key performance indicators, benchmark ranges, and emerging signals in EPR is no longer optional—it is essential for strategic positioning in the circular economy transition.

Why It Matters

Extended Producer Responsibility represents one of the most consequential policy mechanisms for closing material loops and shifting the economic burden of waste management from municipalities to the entities that design, manufacture, and profit from products. The principle is elegant in its logic: by making producers financially and operationally responsible for the full lifecycle of their products, EPR creates direct incentives for eco-design, reduced packaging, improved recyclability, and investment in collection and recycling infrastructure.

The stakes are substantial. According to the Recycling Partnership's 2024 analysis, U.S. states implementing well-designed EPR programs could see recycling rates increase by up to 48 percentage points compared to current baseline rates (Recycling Partnership, 2024). Maryland's needs assessment projected that EPR implementation could boost the state's recycling rate from 34% to over 50%, recover between $13 million and $91 million in material value annually, and create over 2,000 jobs (Maryland Department of Environment, 2024).

Europe's mature EPR frameworks demonstrate what is achievable: the European Economic Area achieved a 66.3% packaging recycling rate and 80.9% recovery rate by 2018, up from 63.9% and 77.9% respectively in 2010 (EEA, 2020). France's textiles EPR program, operational since 2007, has achieved collection rates of 3.7 kilograms per capita—31% of textiles placed on market—compared to an EU-27 average of just 22% (OECD, 2024).

Beyond environmental outcomes, EPR fundamentally reshapes market dynamics. Fee structures increasingly incorporate eco-modulation, where producers of easily recyclable materials pay lower fees while those using problematic materials face premium rates. The UK's 2024 EPR fee structure exemplifies this: plastic packaging incurs approximately £485 per tonne, while paper and cardboard costs roughly £215 per tonne—a 2.25x penalty for harder-to-recycle materials (UK Government, 2024).

Key Concepts

Producer Responsibility Organizations (PROs) serve as the operational backbone of EPR systems. These entities, typically nonprofit and producer-funded, coordinate compliance activities across jurisdictions, aggregate producer fees, contract with recyclers and collection services, and report to regulators. In the United States, the Circular Action Alliance (CAA) has emerged as the dominant multi-state PRO, designated as the official PRO for California, Colorado, Oregon, Minnesota, and Maryland as of early 2025 (Circular Action Alliance, 2025).

Eco-modulation refers to fee structures that differentiate costs based on product recyclability, recycled content, or environmental impact. Colorado's 2026 program will require PROs to establish eco-modulation schedules, creating market signals that reward design for recyclability (Colorado HB 22-1355).

Source reduction targets go beyond recycling to mandate absolute reductions in material use. California's SB 54 exemplifies ambitious reduction mandates: 25% plastic packaging reduction by 2032, 100% recyclable or compostable single-use packaging, and 65% recycling rates for single-use plastics (CalRecycle, 2024). Maine's draft regulations target 60% source reduction by 2050 and 90% collection rates for readily recyclable packaging by 2040 (Maine DEP, 2024).

Digital Product Passports and traceability systems are becoming essential infrastructure for EPR compliance. The EU's Digital Product Passport requirements, taking effect in 2026, will mandate standardized, accessible data on product composition, recyclability, and chain of custody—creating new demands for software platforms that can aggregate, verify, and report this information at scale.

What's Working

Mandatory Recycling Infrastructure Investment

Where EPR programs are mature, recycling infrastructure has expanded significantly. British Columbia's Recycle BC program, one of North America's oldest packaging EPR systems, demonstrates sustained performance with plastic recycling rates approaching 45%—far above voluntary systems (Recycle BC, 2024). The key mechanism: guaranteed, predictable fee revenue enables long-term capital investment in material recovery facilities, collection networks, and processing technology that voluntary programs cannot support.

Fee Transparency Driving Design Changes

The emergence of material-specific fee schedules is catalyzing upstream design decisions. When producers face fees of $0.17–$0.23 per pound in Oregon, multiplied across millions of units shipped annually, the business case for packaging redesign becomes compelling (Oregon DEQ, 2025). Companies report evaluating material switches, lightweighting initiatives, and recyclability improvements with new rigor when the cost of poor design flows directly to their P&L.

Harmonized Multi-State Compliance

The Circular Action Alliance's multi-state infrastructure is reducing compliance complexity for national brands. By providing unified registration portals, harmonized reporting formats targeting annual May 31 deadlines, and consistent data requirements across jurisdictions, CAA addresses a historical barrier to EPR adoption: the fear of fragmented, state-by-state compliance burdens (Circular Action Alliance, 2025).

What's Not Working

Informal Sector Displacement in Emerging Markets

EPR implementation in the Global South faces structural challenges absent from European and North American contexts. Research in India and Ghana indicates that formalized EPR systems can displace informal waste pickers who currently perform the majority of collection and sorting, creating social equity conflicts and sometimes reducing actual collection rates in the short term (Nature Scientific Reports, 2025). Programs that fail to integrate informal sector workers risk undermining both livelihoods and environmental outcomes.

Stakeholder Awareness Gaps

Even in jurisdictions with enacted EPR laws, producer compliance rates remain a concern. Many small and mid-size businesses remain unaware of their obligations, registration requirements, and reporting deadlines. Maine's exemption threshold—businesses under $5 million gross revenue initially, dropping to $2 million—helps, but awareness campaigns have struggled to reach affected entities (Maine DEP, 2024).

Measurement and Verification Challenges

Despite sophisticated fee structures, the actual environmental outcomes of EPR programs remain difficult to verify. Contamination rates in collected materials, actual versus reported recycled content, and the fate of exported recyclables all represent measurement gaps. Without robust verification, eco-modulation risks becoming a paper exercise rather than a genuine driver of material circularity.

Key Players

Established Leaders

Circular Action Alliance (CAA): Founded in 2022 by 20 producers across food, beverage, consumer goods, and retail sectors, CAA has rapidly emerged as the preeminent U.S. PRO. With formal designations in five states and founding members including Keurig Dr Pepper, The Campbell's Company, IKEA Supply AG, and Starbucks Corporation, CAA represents the producer community's collective infrastructure response to EPR mandates.

Recycle BC: Operating since 2014 as the stewardship organization for packaging and paper products in British Columbia, Recycle BC manages a comprehensive collection network serving 99% of provincial residents and processes over 200,000 tonnes annually—a mature model for North American EPR.

Citeo (France): As the PRO for household packaging and paper in France, Citeo coordinates one of Europe's most comprehensive EPR systems, managing over €800 million annually in producer fees and achieving among the highest collection and recycling rates in the EU.

Emerging Startups

Recykal (India): Having raised $40.9 million including a $13.2 million Series A in February 2024 from Morgan Stanley and Circulate Capital, Recykal operates an EPR compliance and waste marketplace platform serving brands navigating India's emerging EPR requirements.

CleanHub: This AI-driven platform provides traceable plastic waste collection and recycling, enabling brands to demonstrate verified EPR compliance through blockchain-verified chain of custody documentation—a critical capability as regulators and consumers demand proof beyond self-reported metrics.

Replenysh: Focused on material lifecycle tracking, Replenysh operates a digital marketplace for traceable recycled materials, helping producers demonstrate recycled content claims and meet emerging mandates like California's recycled content requirements.

Key Investors

Closed Loop Partners: With over 90 investments across 10 countries, Closed Loop Partners is the preeminent dedicated investor in circular economy infrastructure, including EPR compliance technologies, material recovery facilities, and recycling innovation.

Circulate Capital: Focused specifically on ocean plastics and waste management in South and Southeast Asia, Circulate Capital has deployed significant capital into EPR infrastructure and compliance platforms in markets where EPR policy is rapidly emerging.

Circular Innovation Fund: A joint initiative between Demeter and Cycle Capital, this fund targets early-stage circular economy companies, including those developing the software, traceability, and operational infrastructure EPR systems require.

EPR Performance KPIs by Sector

Metric	Benchmark Range	Leading Performance	Notes
Packaging Recycling Rate	45–66%	66.3% (EEA)	US baseline ~27%
Collection Rate	46–90%	90% target (Maine 2040)	Batteries: 46% EU
Source Reduction	25–60%	60% (Maine 2050)	California: 25% by 2032
Fee per Tonne (Plastic)	£400–£500	£485 (UK)	Eco-modulated
Fee per Tonne (Paper)	£180–£250	£215 (UK)	Lowest material fee
Compliance Rate	70–95%	>90% (mature systems)	SME awareness gap
Infrastructure Investment	$50M–$500M	Varies by state	Funded via fees
Jobs Created per State	500–2,500	2,000+ (Maryland est.)	Recycling employment

Examples

Oregon's First-Mover Implementation: In July 2025, Oregon became the first U.S. state to operationalize EPR fee collection under its Plastic Pollution and Recycling Modernization Act (SB 582). The Oregon DEQ approved CAA's program plan in February 2025, with producers invoiced at $0.17–$0.23 per pound based on material type. Non-compliance penalties of up to $25,000 per day underscore regulatory seriousness, while the harmonized CAA infrastructure minimizes producer administrative burden (Oregon DEQ, 2025).
France's Textiles EPR Pioneer: Operational since 2007, France's textiles EPR program through Re_Fashion (formerly Eco-TLC) represents the world's most mature apparel producer responsibility system. By 2019, the program achieved 3.7 kg per capita collection rates—substantially above the EU average—and has catalyzed investment in sorting infrastructure that enables fiber-to-fiber recycling at increasing scale. The Netherlands and Latvia implemented similar textiles EPR programs in 2024–2025, building on the French proof of concept (OECD, 2024).
California's $5 Billion Producer Commitment: California's SB 54, the Plastic Pollution Prevention and Packaging Producer Responsibility Act, represents the most financially significant EPR program in North American history. The law mandates $5 billion in producer fees over ten years beginning in 2027, targeting 25% plastic reduction, 100% recyclable or compostable packaging, and 65% recycling rates by 2032. CalRecycle published covered material categories in July 2024, with producer registration opening in late 2025 (CalRecycle, 2024).

Action Checklist

Conduct a comprehensive packaging and product audit to identify all materials subject to EPR registration across operating jurisdictions, prioritizing states with 2025 compliance deadlines (Oregon, Minnesota, Colorado)
Register with the Circular Action Alliance or applicable PRO before jurisdiction-specific deadlines (April 30, 2025 for Oregon; July 1, 2025 for Minnesota; September 5, 2025 for California)
Implement internal data collection systems capable of reporting packaging weight by material type, recycled content percentages, and units sold by state—the baseline data requirements across U.S. EPR programs
Evaluate packaging portfolio against eco-modulation fee structures, identifying high-fee materials (plastics, multi-layer composites) for potential redesign or substitution to reduce long-term compliance costs
Establish relationships with certified recyclers and material recovery facilities to demonstrate verified end-of-life outcomes and prepare for potential recycled content mandates
Monitor emerging EPR legislation in high-priority markets, including pending bills in New York, New Jersey, Massachusetts, and Hawaii, to anticipate future compliance requirements

FAQ

Q: What is the threshold for EPR registration, and are small businesses exempt?

A: Thresholds vary significantly by jurisdiction. California requires registration for businesses selling covered materials into the state regardless of size, though fee calculations scale with volume. Maine exempts businesses under $5 million gross annual revenue for the first three years, dropping to $2 million thereafter. Oregon and Colorado have lower thresholds, generally capturing businesses selling over 1 tonne of covered packaging annually. Businesses should consult specific state requirements, as exemptions are not uniform.

Q: How are EPR fees calculated, and what determines the amount a producer pays?

A: Fees are typically calculated based on the weight of packaging materials placed on market, differentiated by material type through eco-modulation. Oregon's 2025 fees range from $0.17–$0.23 per pound, with plastics at the higher end and paper at the lower. Total fees equal weight multiplied by the per-unit rate, with adjustments for recycled content (reducing fees) and recyclability (favoring easily recyclable materials). California's program will collect approximately $500 million annually from producers starting 2027.

Q: What happens if a producer fails to register or report under an EPR program?

A: Non-compliance penalties are substantial and escalating. Oregon imposes penalties up to $25,000 per day for violations. California's SB 54 authorizes penalties up to $50,000 per day beginning in 2027. Beyond financial penalties, unregistered producers may face sales bans for non-compliant products and reputational consequences as retailers increasingly require EPR compliance as a procurement condition.

Q: How should multinational companies approach compliance across different EPR regimes?

A: Companies operating across multiple EPR jurisdictions should centralize packaging data collection using standardized metrics (weight by material, recycled content, recyclability classification) that satisfy the most demanding reporting requirements. Working with multi-jurisdiction PROs like CAA in the U.S. and established PROs in Europe reduces fragmentation. Companies should also monitor the EU's Packaging and Packaging Waste Regulation (PPWR) and Digital Product Passport requirements, which will create additional harmonized standards by 2026–2027.

Q: Will EPR fees increase over time, and how should companies budget for future costs?

A: EPR fees are designed to cover the full cost of collection, sorting, recycling, and program administration—costs that will rise as infrastructure expands and recycling targets increase. California's program alone targets 65% recycling rates by 2032, requiring significant infrastructure investment funded through fees. Companies should model fee escalation scenarios of 5–10% annually and prioritize packaging redesign investments that reduce material weight and improve recyclability, as these actions directly reduce long-term fee exposure.

Sources

OECD. (2024). Extended Producer Responsibility in the Garments Sector. OECD Environment Working Papers No. 253.
Recycling Partnership. (2024). Increasing Recycling Rates with EPR Policy. https://recyclingpartnership.org/eprreport/
Circular Action Alliance. (2025). Producer Resource Center: State-by-State Compliance Guidance. https://circularactionalliance.org
CalRecycle. (2024). SB 54: Plastic Pollution Prevention and Packaging Producer Responsibility Act Implementation. https://calrecycle.ca.gov/packaging/packaging-epr/
European Environment Agency. (2020). Packaging Waste Statistics. EEA Data and Maps.
UK Government. (2024). Extended Producer Responsibility for Packaging: Who Is Affected and What to Do. https://www.gov.uk/guidance/extended-producer-responsibility-for-packaging
Maryland Department of Environment. (2024). Producer Responsibility Needs Assessment. https://mde.maryland.gov/programs/land/WasteManagement/Pages/ProducerResponsibility.aspx
Oregon Department of Environmental Quality. (2025). Plastic Pollution and Recycling Modernization Act Implementation. https://www.oregon.gov/deq/recycling
Proskauer Rose LLP. (2025). Seven States and Counting: The 2025 Guide to EPR Packaging Compliance. https://www.proskauer.com/alert/the-2025-guide-to-epr-packaging-compliance