ACHIEVE ENVIRONMENTAL provides objective analysis and technical support related to Extended Producer Responsibility programs. We work with producers, public agencies, local governments, recycling organizations, and community stakeholders to evaluate regulatory requirements, program data, and environmental outcomes.
Our Role
Our role is to present clear, defensible findings.
Services
Regulatory Applicability
Packaging EPR requirements are established primarily at the state level. Each program defines its own covered materials, producers, exemptions, reporting requirements, fees, and implementation schedule.
ACHIEVE ENVIRONMENTAL can support evaluations of:
Whether an organization meets the applicable definition of a producer
Which packaging, paper products, or other materials are covered
Available exclusions, exemptions, and minimum thresholds
Registration and Producer Responsibility Organization requirements
Material reporting and recordkeeping obligations
Applicable fees, deadlines, and compliance schedules
Differences among state programs
Current state packaging programs include:
California SB 54: Establishes an EPR program for single-use packaging and plastic food-service ware. Permanent regulations became effective May 1, 2026. The law establishes source-reduction, recycling, and recyclability or compostability goals for covered materials.
Colorado HB 22-1355: Establishes a producer-funded statewide recycling program for covered packaging and paper products.
Maine, 38 M.R.S. § 2146 and Chapter 428: Establishes a packaging stewardship program involving producer payments, reporting, municipal reimbursement, and state oversight. Implementation remains in progress.
Maryland Packaging and Paper Products–Producer Responsibility Plans Act: Establishes producer-responsibility requirements for covered packaging and paper products. The law was enacted in 2025, with implementing regulations finalized in 2026.
Minnesota Packaging Waste and Cost Reduction Act: Covers packaging, food packaging, and paper products. It requires covered producers to participate in a Producer Responsibility Organization, subject to the law’s schedule and exemptions. Implementation and rulemaking are ongoing.
Oregon Plastic Pollution and Recycling Modernization Act: Requires covered producers to register with an approved Producer Responsibility Organization, report covered-product data, and pay applicable fees. Producer obligations began in 2025.
Washington Recycling Reform Act: Establishes an EPR program for residential packaging and paper products. Producers are required to participate in and fund a Producer Responsibility Organization according to the statutory implementation schedule.
Packaging and Material Data
Accurate material information is central to EPR reporting and program evaluation. Relevant work may include:
Reviewing packaging and paper-product inventories
Evaluating material classifications and reported weights
Reviewing recycled-content and recyclability information
Identifying missing or inconsistent data
Evaluating supplier documentation
Reviewing the basis for exemptions or exclusions
Documenting data sources, assumptions, and limitations
Program and Fee Evaluation
EPR programs may assign financial and operational responsibilities to producers while providing funding for collection, processing, education, infrastructure, or municipal reimbursement.
ACHIEVE ENVIRONMENTAL can evaluate:
Producer fee structures and supporting assumptions
Material categories and fee-modulation criteria
Collection and processing cost information
Reported recycling, recovery, or reuse rates
Program plans and annual reports
Municipal reimbursement methodologies
Performance targets and measurement methods
Transparency, public participation, and accountability provisions
Stakeholder Communication
EPR programs affect producers, recyclers, waste-service providers, municipalities, consumers, and communities. Support may include:
Plain-language explanations of regulatory requirements
Technical review of proposed program plans
Documentation of stakeholder questions and concerns
Review of public reports and performance information
Public meetings and technical presentations
Independent summaries of program data and implementation status
Requirements and deadlines vary by state and may change through legislation, rulemaking, agency guidance, or approved program plans. Applicability should therefore be evaluated for the relevant jurisdiction, material, and organization.
Talk to Us About EPR Requirements
Need to understand how state EPR programs apply to your organization or program? Contact us to talk through your questions.