EPR: Important Update for WCP Customers
Dear Valued Customer:
Seven U.S. States have now passed Extended Producer Responsibility (EPR) laws aimed at addressing the Plastic Pollution and Recycling Modernization Act: Oregon, Colorado, California, Maine, Minnesota, Maryland, and Washington. Several other states also have EPR legislation currently under consideration. These laws focus on improving recycling programs by requiring manufacturers, and brand owners, to take financial responsibility for paper, packaging, and foodservice products placed in the marketplace. The overall goal is to reduce landfill waste, improve recycling systems, and encourage environmentally friendly product design.
The EPR laws are designed to fund the cost of managing various types of waste. They mandate “producer” responsibilities through fees for certain materials or products. The “producer” can be the manufacturer, the first importer, or the brand owner, and fees are calculated by the tons sold in specific product categories. These programs use the “eco modulation” concept to determine how fees are applied. Materials that are easier and less costly to recover, such as paper or corrugated products, may be charged less per pound than harder-to-recycle items like clamshell food containers or disposable cups.
Oregon is the first state to require self-reported fees, effective July 1, 2025. These fees will be retroactive for all “producers” based on their 2024 tonnage sold in each applicable product category. We expect the other states to soon follow similar but different fee structures. These changes will result in additional costs for paper and packaging products and will increase complexity when moving goods across state lines.
There is considerable industry discussion about the administration and implementation of these new regulations. Some organizations have raised concerns, including the possibility of litigation, and WCP will continue to monitor developments closely to understand how they may impact our customers.
WCP Solutions offers a number of ways to support our customers. We always want to be a resource and will provide education and information as much as we can as these laws continue to develop. A good starting point that we encourage you to look at is the FAQ published by Pregis, which does a good job explaining how EPR could impact your business. The WCP team can also help by providing product support with options like down-gauging, which means using thinner and lighter materials where possible, and right-sizing, which focuses on reducing excess packaging to better fit the product. We also offer support for converting to paper or pulp-based alternatives where it makes sense.
We appreciate your business and your continued support.
Sincerely,
Ed Allen
President, WCP Solutions
