Regulatory tracker: Extended Producer Responsibility (EPR) rules by jurisdiction — what's live, pending, and proposed

As of Q1 2026, Extended Producer Responsibility (EPR) obligations cover an estimated $45 billion in annual producer fees globally, with the number of active EPR schemes expanding from 415 in 2020 to over 690 across 85 countries (OECD, 2025). For procurement professionals operating across multiple jurisdictions, tracking this regulatory patchwork is no longer optional: non-compliance penalties in the EU now reach up to 4% of annual turnover under the revised Packaging and Packaging Waste Regulation, and at least 12 US states have enacted or are actively implementing packaging EPR laws since 2021. This tracker maps the current enforcement landscape, identifies pending regulations, and flags proposed rules that will reshape producer obligations in emerging markets over the next 24 months.

Why It Matters

EPR shifts the financial and operational responsibility for end-of-life product management from municipalities and taxpayers to the companies that place products on the market. The principle is straightforward, but implementation varies enormously across jurisdictions: fee structures, covered materials, collection targets, recycled content mandates, and enforcement mechanisms differ in ways that create significant compliance complexity for multinational producers and their procurement teams.

The financial exposure is substantial. In the European Union, packaging EPR fees for a mid-sized consumer goods company typically range from EUR 5 million to EUR 25 million annually, depending on material mix, volumes, and member state fee schedules. In France, where eco-modulation penalties for non-recyclable packaging can increase base fees by 100%, a single packaging design decision can shift annual EPR costs by millions of euros (CITEO, 2025). In the United States, the emergence of state-level packaging EPR programs is introducing new cost categories for companies that previously bore no end-of-life obligations for packaging sold domestically.

Beyond direct fees, EPR regulations increasingly incorporate performance requirements that affect procurement specifications: minimum recycled content mandates, design-for-recyclability standards, and restrictions on problematic materials. The EU's Packaging and Packaging Waste Regulation (PPWR), adopted in late 2024, mandates that all packaging placed on the EU market must be recyclable by 2030 and recycled at scale by 2035, with minimum recycled content targets of 35% for PET contact-sensitive packaging and 65% for other PET packaging by 2030 (European Commission, 2024).

For procurement teams, EPR compliance requires coordinating across packaging design, material sourcing, supplier management, and regulatory reporting. The cost of reactive compliance, including retroactive fee adjustments, penalties, and emergency packaging redesigns, consistently exceeds the cost of proactive monitoring and planning by a factor of three to five, according to analysis by the Extended Producer Responsibility Alliance (EXPRA, 2025).

EPR Regulatory Status by Jurisdiction

European Union

Status: Live and expanding

The EU operates the world's most comprehensive EPR framework, with mandatory schemes covering packaging, electronics (WEEE), batteries, end-of-life vehicles, and textiles. Key developments in 2025-2026 include:

Packaging and Packaging Waste Regulation (PPWR): Adopted December 2024, the PPWR replaces the 1994 Packaging Directive with a directly applicable regulation, eliminating member state transposition differences. Key provisions include: mandatory recyclability assessment for all packaging by 2030; minimum recycled content targets (30% for contact-sensitive PET, 10% for other plastics by 2030, rising to 65% and 30% respectively by 2040); deposit return scheme requirements for single-use plastic beverage containers and aluminum cans by 2029; and restrictions on certain single-use packaging formats in the hospitality sector by 2030. EPR fee eco-modulation based on recyclability, recycled content, and repairability becomes mandatory across all member states by 2027 (European Commission, 2024).

EU Textiles Strategy and textile EPR: France implemented the world's first mandatory textile EPR scheme through Re_fashion (formerly Eco-TLC) in 2008, collecting EUR 280 million in producer fees in 2025. The EU's proposed Ecodesign for Sustainable Products Regulation includes provisions enabling EU-wide textile EPR harmonization, with the European Commission expected to publish delegated acts specifying textile EPR requirements by mid-2026. The Netherlands, Sweden, and Hungary have enacted or proposed national textile EPR schemes ahead of EU harmonization.

Batteries Regulation: The EU Batteries Regulation (2023/1542), effective February 2024, establishes EPR obligations for all battery types, including industrial, EV, and portable batteries. Producers must finance collection, treatment, and recycling, with collection targets of 63% for portable batteries by 2027 and 73% by 2030. Minimum recycled content requirements for cobalt (16%), lead (85%), lithium (6%), and nickel (6%) take effect in 2031.

United States

Status: Rapidly emerging at state level; no federal framework

The US lacks federal EPR legislation, but state-level activity has accelerated dramatically. As of Q1 2026:

Live programs: Colorado (HB 22-1355, operational 2025), Oregon (SB 582, operational 2025), California (SB 54, phased implementation 2025-2032), and Maine (LD 1541, operational 2026) have enacted packaging EPR laws. Colorado's program, administered by the Circular Action Alliance, collected initial producer fees in Q3 2025, with full fee schedules reflecting material-specific recycling costs effective in 2026. California's SB 54 is the most ambitious, requiring a 25% reduction in single-use plastic packaging by 2032 and 65% recycling rates for all single-use packaging and food service ware by 2032, with a producer responsibility organization (PRO) managing $5 billion or more in cumulative producer investments (CalRecycle, 2025).

Pending implementation: New York's Packaging Reduction and Recycling Infrastructure Act, signed in 2025, establishes packaging EPR with implementation beginning in 2027. Maryland and Washington State have enacted EPR frameworks with rulemaking in progress. Illinois and New Jersey have advanced packaging EPR bills through committee with expected passage in 2026.

Proposed: At least 18 additional states introduced packaging EPR legislation in 2025 legislative sessions. The Break Free From Plastic Pollution Act, reintroduced at the federal level, would establish national packaging EPR and container deposit requirements, though passage remains unlikely in the current Congress.

Electronics (e-waste) EPR: 25 US states and the District of Columbia operate e-waste EPR or e-waste recycling programs. California's e-waste program, funded through a consumer advance recovery fee (ARF), collected $89 million in 2025. Harmonization efforts through the Electronics Recycling Coordination Clearinghouse (ERCC) have standardized some reporting requirements, but material differences in covered devices, reporting obligations, and fee structures persist across states.

Canada

Status: Live across most provinces

Canada operates a mature, province-led EPR system. British Columbia's Recycle BC program, one of the most comprehensive globally, achieved a 78% packaging recovery rate in 2025. Ontario transitioned packaging EPR from a shared-responsibility model to full producer responsibility through the Blue Box Transition, completed in 2025, shifting approximately CAD 325 million in annual costs from municipalities to producers. Quebec, Alberta, Saskatchewan, and Manitoba operate EPR programs for packaging, electronics, and hazardous materials with varying scope and fee structures. The Canadian Council of Ministers of the Environment published a Canada-wide Action Plan on EPR in 2024, targeting harmonized packaging EPR requirements across all provinces by 2028 (CCME, 2024).

India

Status: Live with expanding scope

India's EPR framework for plastic packaging, established under the Plastic Waste Management Rules (2022 amendments), requires producers, importers, and brand owners (PIBOs) to register on the Central Pollution Control Board (CPCB) portal and meet annual collection and recycling targets. As of 2025-2026, targets require PIBOs to collect and recycle 80% of rigid plastic packaging and 60% of flexible and multi-layered plastic packaging. The EPR credit trading system, launched in 2024, allows surplus compliance credits to be traded on the CPCB portal, though market liquidity and pricing transparency remain limited. E-waste EPR, governed by the E-Waste Management Rules (2022), covers 21 categories of electrical and electronic equipment with collection targets reaching 70% of sales by weight by 2025 (CPCB, 2025).

Brazil

Status: Live for specific sectors; packaging EPR expanding

Brazil's National Solid Waste Policy (PNRS, 2010) established the legal basis for EPR, with sector-specific agreements covering tires, lubricant oil, batteries, pesticide containers, and electronics. Packaging EPR implementation through sectoral agreements has been slower, with a proposed regulation under consultation in 2025 that would mandate packaging reverse logistics systems operated by PROs. Sao Paulo state has enacted its own packaging EPR requirements ahead of national legislation, requiring producers to demonstrate collection and recycling of 22% of packaging placed on the market by 2025, rising to 50% by 2030. The Brazilian Association of Packaging (ABRE) estimates compliance costs of BRL 2 to 4 billion annually once national packaging EPR is fully implemented (ABRE, 2025).

Southeast Asia

Status: Mostly proposed; early adoption in select markets

Indonesia's EPR regulation (Government Regulation No. 27/2020) requires producers of packaging, electronics, and tires to implement waste reduction and handling plans, with mandatory targets effective from 2023. However, enforcement has been limited, and compliance verification infrastructure remains underdeveloped. Vietnam's 2022 Law on Environmental Protection includes EPR provisions for packaging, batteries, tires, lubricants, and electronics, with collection and recycling obligations phased in from 2024. Thailand published a draft EPR framework for packaging in 2025, with stakeholder consultation ongoing. The Philippines has no national EPR legislation, though the Extended Producer Responsibility Act (SB 1331) has been filed in the Senate.

EPR Compliance Requirements: Cross-Jurisdiction Comparison

Requirement	EU (PPWR)	US (California SB 54)	Canada (Ontario)	India	Brazil (Proposed)
Registration Deadline	Varies by member state	2025 (initial)	2025 (completed)	Annual renewal	TBD
Covered Materials	All packaging	Single-use packaging, food service ware	Printed paper, packaging	Plastic packaging	All packaging
Recycling Rate Target	65% by 2025, 70% by 2030	65% by 2032	75% by 2030	80% rigid, 60% flexible	50% by 2030
Recycled Content Mandate	Yes (material-specific)	30% plastic by 2028	Under development	No	Under discussion
Eco-Modulation	Mandatory by 2027	Required in fee structure	Optional	No	Proposed
Deposit Return Scheme	Mandatory by 2029	Not required	Some provinces	No	Under discussion
Reporting Frequency	Annual	Annual	Annual/Quarterly	Annual	Annual
Penalties for Non-Compliance	Up to 4% of turnover	Up to $50,000/day	Up to CAD 200,000	Up to INR 1 million	TBD

Practical Guidance for Procurement Teams

Immediate Actions (2026)

Procurement teams should conduct a comprehensive audit of packaging materials and volumes across all markets where they place products. For EU operations, assess recyclability of all packaging formats against the PPWR criteria published in Annex II, identifying formats that will require redesign before the 2030 recyclability deadline. In the US, register with PROs in Colorado, Oregon, California, and Maine, ensuring that reporting systems capture the material-specific data required for fee calculations. For India, verify registration on the CPCB portal and establish EPR credit procurement strategies to cover any shortfall between actual collection performance and mandated targets.

Medium-Term Planning (2026-2028)

Redesign packaging to maximize recyclability and incorporate recycled content in anticipation of mandatory targets. The cost premium for food-grade recycled PET (rPET) has decreased from 40% above virgin PET in 2023 to approximately 15% in 2025, though supply remains constrained. Procurement specifications should include recycled content requirements aligned with the most stringent applicable jurisdiction to avoid maintaining parallel packaging specifications. Engage with PROs to understand eco-modulation fee schedules and design packaging that qualifies for fee reductions rather than penalties.

Long-Term Strategy (2028-2032)

Anticipate convergence of EPR requirements across jurisdictions toward higher recycling targets, mandatory recycled content, and restrictions on non-recyclable formats. Companies operating in 10 or more EPR jurisdictions should evaluate centralized compliance management platforms such as those offered by Lorax Compliance, PackagingLaw.com, or EY's EPR advisory practice. Total compliance costs can be reduced by 20-30% through standardized packaging portfolios designed to meet the most stringent applicable requirements across all markets (EXPRA, 2025).

Key Organizations and Resources

OECD EPR Working Group publishes the most comprehensive comparative analyses of EPR policies, including the biennial Extended Producer Responsibility: Updated Guidance for Efficient Waste Management (OECD, 2024).

Extended Producer Responsibility Alliance (EXPRA) represents PROs across 27 countries and provides compliance intelligence, benchmarking data, and policy analysis.

Ellen MacArthur Foundation maintains the Global Commitment progress reports tracking voluntary packaging commitments by more than 500 signatories, providing benchmarks for recycled content and reuse targets.

Lorax Compliance offers a commercial EPR regulatory tracking platform covering 60+ jurisdictions with automated obligation monitoring and reporting tools.

Action Checklist

• Inventory all products and packaging subject to EPR obligations across every market of operation
• Register with PROs and regulatory portals in all jurisdictions with active EPR schemes
• Map current packaging materials against recyclability criteria in EU PPWR Annex II
• Assess recycled content levels in current packaging against pending mandatory targets
• Establish data systems capturing material type, weight, and volume data at SKU level for EPR reporting
• Review supplier contracts for recycled content specifications and supply security
• Model EPR fee exposure under eco-modulated fee schedules to quantify packaging redesign ROI
• Monitor legislative developments in US states, Brazil, and Southeast Asia for new EPR obligations
• Evaluate centralized EPR compliance management platforms for multi-jurisdiction operations
• Engage with industry PROs to influence fee structures and collection infrastructure investments

Sources

• OECD. (2025). Extended Producer Responsibility: Updated Guidance for Efficient Waste Management, 2025 Edition. Paris: OECD Publishing.
• European Commission. (2024). Regulation on Packaging and Packaging Waste (PPWR): Final Adopted Text. Brussels: Official Journal of the European Union.
• CalRecycle. (2025). SB 54 Implementation Progress Report: Producer Responsibility Organization Registration and Fee Assessment. Sacramento: California Department of Resources Recycling and Recovery.
• Canadian Council of Ministers of the Environment. (2024). Canada-wide Action Plan on Extended Producer Responsibility. Winnipeg: CCME Secretariat.
• Central Pollution Control Board. (2025). EPR Portal Annual Compliance Report: Plastic Packaging and E-Waste. New Delhi: CPCB.
• CITEO. (2025). Annual Report 2025: Eco-Modulation Barometer and Fee Schedule Analysis. Paris: CITEO.
• Extended Producer Responsibility Alliance. (2025). Cost of Compliance: Proactive vs. Reactive EPR Management Across Multinational Operations. Brussels: EXPRA.
• Associacao Brasileira de Embalagem. (2025). EPR Implementation Impact Assessment for Brazilian Packaging Sector. Sao Paulo: ABRE.