The U.S.’s Extended Producer Responsibility (EPR) Landscape: What You Need to Know

Article Highlights:

• Extended Producer Responsibility (EPR) is a policy approach that shifts responsibility for the end-of-life management of products and packaging from municipalities and taxpayers to producers. At its core, EPR means that companies placing products on the market are financially, and often operationally, responsible for collecting, recycling, or properly disposing of those products once consumers are finished with them.
• As of 2026, the U.S. packaging EPR landscape is concentrated in a set of leading U.S. states, each with unique program characteristics. 
• Extended producer responsibility laws impose direct obligations on “producers,” a term that’s defined differently by each state but typically includes brand owners, importers, and manufacturers placing covered products or packaging into the market. 

Extended Producer Responsibility, commonly referred to as EPR, is no longer a niche environmental policy concept in the United States. Over the past several years, EPR laws in the U.S. have accelerated rapidly, particularly at the state level, reshaping how producers think about packaging, product design, reporting, and end-of-life management. For companies placing goods on the U.S. market, understanding extended producer responsibility laws is now less a forward-thinking sustainability exercise than a strategic imperative. As 2026 EPR compliance deadlines approach, producers must understand not only what EPR means but also how evolving state requirements translate into operational, financial, and legal obligations—as well as what proactive steps can mitigate compliance risks.

What Is Extended Producer Responsibility (EPR)?

Extended Producer Responsibility is a policy approach that shifts responsibility for the end-of-life management of products and packaging from municipalities and taxpayers to producers. 

At its core, EPR means that companies placing products on the market are financially, and often operationally, responsible for collecting, recycling, or properly disposing of those products once consumers are finished with them. Traditional waste management systems in the U.S. have largely relied on local governments to fund and manage recycling and disposal programs. Under EPR frameworks, on the other hand, producers internalize these costs, creating an economic incentive for better product and packaging design while also encouraging recyclability, material reduction, and improved circularity. By embedding end-of-life considerations directly into product stewardship and supply chain strategy, EPR moves responsibility upstream, reducing the burden on municipalities while promoting sustainable materials management.

Why EPR Is Growing in the United States

The rapid expansion of EPR laws in the U.S. is driven by several converging factors. First, municipal recycling systems are now facing chronic funding gaps. In addition, commodity price volatility, contamination, and rising processing costs have strained local budgets. States increasingly view EPR as a mechanism to stabilize recycling funding by shifting costs upstream to producers. 

Second, corporate sustainability commitments and climate targets have raised expectations around material efficiency and circular economy performance. EPR aligns closely with circular economy principles: it promotes waste reduction, circular design, and extended material lifecycles. 

Third, growing public awareness of plastic pollution, battery fires, and electronic waste has heightened the political appetite for a more sweeping, systemic reform. This combination of fiscal, environmental, and societal pressures directly informs the evolving state-level requirements that producers must now track to remain compliant—and it underscores why EPR is gradually becoming a standard part of the U.S.’s larger regulatory system. 

Current U.S. EPR Laws and Landscape

The most significant recent development in extended producer responsibility laws has been the adoption of packaging EPR programs. Maine and Oregon were early adopters, passing packaging EPR laws in 2021. In the years since, California, Colorado, Minnesota, Maryland, and Washington have enacted legislation establishing producer-funded systems for packaging and paper products.

As of 2026, the U.S. packaging EPR landscape is concentrated in a small subset of forward-thinking states, each with unique program characteristics: 

• Maine’s program is fully operational, with producer registration, annual reporting, and fee obligations in full effect. 
• Oregon’s program begins reporting in 2026, with full fee obligations phased in afterward. California is currently in baseline data collection and registration phases, with fee implementation scheduled for 2027. 
• Colorado and Minnesota have recently passed legislation emphasizing programs run by producer responsibility organizations (PROs) and phased reporting timelines, while Maryland and Washington are finalizing rules that include tiered fees and eco-modulation incentives. 

Across these states, materials covered by EPR regulations generally include paper, glass, metal, and plastic. Thresholds, exemptions, and fee calculations often differ between jurisdictions, however, reflecting a patchwork approach that requires multistate producers to maintain detailed tracking systems and cross-functional compliance teams. Collectively, this snapshot illustrates how EPR state requirements vary, highlighting the growing pressure on producers to monitor deadlines, fee structures, and program updates.

Maine and Oregon were early adopters, passing packaging EPR laws in 2021. In the years since, California, Colorado, Minnesota, Maryland, and Washington have enacted legislation establishing producer-funded systems for packaging and paper products.

2026 EPR Key Deadlines and Compliance Milestones

For many producers, 2026 represents a milestone year for EPR compliance. At various points in the year, several states will implement active reporting obligations, fee schedules, and formalized participation requirements. 

In Oregon, producers are required to submit annual reports detailing packaging volumes and material types, with fee obligations tied to those disclosures. California’s program includes baseline data reporting and producer registration requirements ahead of full program implementation in 2027. And other states are finalizing their rules, setting performance targets, and establishing harmonized data frameworks. 

While harmonization discussions are underway across states, full uniformity does not yet exist. Producers operating nationally must track evolving EPR state requirements carefully, ensuring that reporting methodologies, material classifications, and registration processes align with each jurisdiction’s regulatory framework. Establishing internal compliance calendars, data collection workflows, and audit-ready records can save significant time and expense when deadlines arrive.

How EPR Laws Affect Businesses

Extended producer responsibility laws impose direct obligations on “producers,” a term that’s defined differently by each state but typically includes brand owners, importers, and manufacturers placing covered products or packaging into the market. Producers may be required to register with a state-approved producer responsibility organization (PRO), submit detailed data reports on packaging quantities, pay eco-modulated fees, and maintain records for audit purposes. For businesses, this means EPR compliance is not just a reporting exercise: it affects product design, procurement, and financial planning. 

Companies should establish cross-functional teams to manage compliance, integrate supplier data collection, and anticipate fee liabilities. Strategic responses often include redesigning packaging to reduce weight or switch to more recyclable materials, upgrading supply chain data systems, and aligning long-term product development with EPR compliance timelines. Proactive planning helps mitigate financial risk, avoid penalties, and position a business as an environmentally responsible producer.

Beyond Packaging: Emerging EPR Areas

While packaging remains the most prominent EPR category, new policy developments are expanding the scope of the regulatory framework. The U.S. Environmental Protection Agency has explored a national battery stewardship framework, reflecting concerns about lithium-ion battery fires and recycling challenges. Several states are advancing battery EPR legislation, aiming to create consistent collection and recycling pathways. Electronics EPR laws already exist in numerous states, and modernization efforts are underway to update covered device lists and performance targets. Textiles are also gaining attention as states consider landfill diversion strategies and circular economy initiatives. These developments illustrate how extended producer responsibility laws are evolving beyond traditional packaging models into broader product stewardship systems. 

As of 2026, several states are taking the lead on EPR programs that go beyond packaging:

• Oregon, California, and Washington have active or planned battery stewardship programs, requiring producer registration, collection plan submissions, and reporting on lithium-ion battery volumes. 
• Maine and Colorado are exploring pilot programs for rechargeable batteries, and several other states, including Minnesota and Maryland, are considering textile collection and recycling frameworks. 
• California’s and Washington’s programs are still under development and not yet fully mandatory.

Electronics EPR continues to expand, too, with New York and New Jersey updating device lists and setting collection targets. 

While each program differs in scope, fee structure, and reporting requirements, the emerging landscape sends a clear signal that EPR will not be limited to packaging materials and recycling in the years to come. Regulators are broadening their focus to encompass batteries, electronics, and textiles—developments that manufacturers will need to start incorporating into their supply chain strategies.

While each program differs in scope, fee structure, and reporting requirements, the emerging landscape sends a clear signal that EPR will not be limited to packaging materials and recycling in the years to come.

U.S. EPR Trends vs. Global EPR Trends

Globally, EPR has long been implemented through more centralized regulatory frameworks. The European Union, for example, has established robust EPR programs for packaging, complete with standardized reporting requirements, eco-modulated fees, and recycling performance targets. These programs exist under directives such as the Packaging and Packaging Waste Directive (PPWD). 

Meanwhile, Canada has implemented comprehensive EPR programs covering packaging, electronics, and hazardous materials. In comparison, U.S. EPR laws remain largely state-driven, resulting in a more fragmented regulatory landscape. But the U.S.’s state-level programs are influenced by international models, as evidenced by their use of eco-modulated fees to incentivize recyclable materials, as well as standardized reporting formats that reduce administrative burden. 

Multinational producers can leverage these insights to streamline U.S. compliance by aligning internal reporting systems with proven international frameworks.

EPR FAQs for Stakeholders

Do I need to register for EPR in every state?

The answer depends on where your company places covered products or packaging on the market and whether you meet each state’s producer definition and de minimis thresholds. In most cases, when you sell in a state with active EPR laws and exceed minimum thresholds, you’ll need to register either directly or through a Producer Responsibility Organization.

What fees will my company pay?

Fees vary by state and are typically calculated based on material type, weight, and recyclability. Some programs use eco-modulation to reward recyclable or lower-impact materials. Because fee schedules are still being finalized in several states, companies should treat EPR compliance as a budgeting and forecasting exercise as much as a regulatory one.

How does EPR impact my supply chain responsibilities?

EPR obligations often require upstream data on packaging composition and weights, creating new information flows between suppliers and brand owners. Companies may need to revise supplier contracts, implement data management systems, and align packaging specifications with recyclability standards. Over time, EPR may influence material selection, product design, and logistics decisions, making early supply chain engagement critical.

Growing EPR Responsibilities and the Tools to Navigate Them

Looking ahead, legislative momentum suggests that additional states will adopt extended producer responsibility laws in the coming years. Packaging EPR is likely to expand geographically, too, with additional states expected to pass programs over the next two years. 

Battery and textile frameworks are gaining traction as well, with new legislation in several states expected to address lithium-ion recycling, textile waste diversion, and electronics stewardship. Federal coordination also remains a possibility, potentially establishing baseline requirements or harmonized reporting guidelines to reduce the current patchwork. 

For businesses, the obligations EPR imposes on producers will continue to evolve, expanding into a more strategic consideration that impacts product design, supply chain management, and sustainability reporting. Businesses that want to stay on top of EPR regulations and other compliance responsibilities will want to consider a compliance tool like Z2. Compliance software Z2 provides a comprehensive compliance solution for emerging EPR directives and other regulatory responsibilities, one that uses four key pillars to deliver industry-leading intelligence and support:

• Data Framework and Normalization
• Due Diligence
• Compliance Risk Analysis
• Reports and Certificates

Manufacturers that are able to draw on the multifaceted approach used by Z2 will have a much easier time achieving compliance in a timely, efficient fashion that does not compromise production or drain internal resources. 

To learn more about Z2 and its full-service compliance software, schedule a free trial with one of our product experts.