Navigating EPR Compliance

Organizations representing brand owners and packaging companies are calling for greater harmonization across extended producer responsibility laws and legislation, where proliferation has added layers of complexity to compliance.

The spread of packaging EPR in the United States happened slowly — then very quickly.

“It took years to get to the first two states” — Maine and Oregon — but then within a period of a few years, “it went from two states to seven states with enacted laws,” said Danielle Waterfield, Ameripen’s policy director.

There could be benefits to states saying “‘oh, yeah, me too, what they did,’ but they're not doing that,” Waterfield said. “The first few states started very independent with their own ideas. You had Maine with East Coast perspectives, and you had Oregon with very different West Coast perspectives,” reflecting unique economic and cultural factors, and resulting in varied definitions, timelines and frameworks.

Still, there’s much consensus among stakeholders that areas such as producer definitions and covered material categories could be more aligned across states. But what would it mean to harmonize, and what’s possible?

National consistency, regional flexibility

Groups representing producer interests are generally calling for greater harmonization, while maintaining some state-to-state flexibility.

The EPR Leadership Forum, which represents manufacturers and retailers of consumer packaged goods, shared its position on harmonization opportunities this fall. It’s more focused on affecting change in future programs versus working to harmonize existing ones.

When the forum talks about harmonization, “I think what we're really talking about is developing some sort of national consistency, while allowing for regional flexibility” in program plans and “rates and dates,” said Alchemy Graham, policy director at the EPR Leadership Forum. Put another way, it’s important to have “a standardized, consistent framework that we can all work off of and tailor to individual state recycling markets and state infrastructure needs as necessary.” 

First thing’s first, it’s important to harmonize basics like producer and recycling definitions, as well as covered material lists. “I think that once we can get those particular things harmonized, then we'd be in a really good place to move forward with other definitions and other pieces of the framework,” Graham said.

The forum will focus heavily on legislator education in 2026. “We really want to get in the door and have those conversations before the legislation is developed,” Graham said.

The U.S. Plastics Pact also recently released a policy position paper on EPR. “While harmonization of core elements such as definitions, scope, and performance metrics is essential to reduce complexity and administrative burden, flexibility is equally important to accommodate state-specific realities such as infrastructure, data availability, and market conditions,” USPP wrote.

Coordination led by a producer responsibility organization will also be key for multi-state harmonization, in lieu of federal harmonization, USPP wrote.

PRO’s perspective

Creating a stronger foundation across state programs can start with the producer responsibility organization playing a central role in needs assessments, according to Shane Buckingham, chief of staff at Circular Action Alliance, the PRO active in numerous U.S. states. “Our preference is to manage the needs assessment process” as a first step in development, Buckingham said.

The national nature of CAA is designed to be a strength, “to ensure that we can deliver consistent reporting and compliance to producers,” Buckingham said. Like others, he highlighted covered material categories as among the key areas for harmonization, noting different approaches across multiple states.

“So for instance, California, it establishes its own covered material categories which can be updated on an annual basis. Oregon: We established the reporting categories, but then they needed to be approved as part of the program plan. In Colorado, we were able to map those reporting categories. But then in Minnesota and Maryland, we were going to have to go through a state-led process on the development of covered material categories,” Buckingham explained.

In Minnesota and Maryland, for instance, CAA intends to establish its own early reporting process using simplified categories. “However, if a state has a requirement for the regulator to establish the covered material categories, then we will need to use those categories going forward,” Buckingham said.

If a national list were established, then “that can cascade into the appropriate categories by state,” but CAA is already seeing too much variation in this area, “so that that is something that will likely need to be worked out over time.”

Adjustments that require rules changes would be time-intensive. “From our perspective, we're going to do everything we can to ensure the greatest harmonization, to the greatest extent possible, without further regulatory change,” Buckingham said.

With some of the earliest laws, “when these EPR bills were being discussed, people were working with the information they had at the time,” Buckingham said. But there have been some more recent positive signs for harmonization: “We've started to see consistency in the producer definition from Minnesota to Maryland to Washington.”

It’s a normal part of the policy process to “look back and reflect on what works well and what is creating an unnecessary challenge in implementation,” he said.

Different priorities, different programs

Another area that CAA highlighted for harmonization is responsible end markets.

“Having a national standard that we can apply to identify, verify and audit responsible end markets is very important,” Buckingham said, noting CAA was recently working to establish a standard development committee focused on this topic.

The Oregon Department of Environmental Quality hears those calls, said Program Plan Lead Nicole Portley, and sees some potential there for harmonization, including through a single auditing method for the downstream facilities that could be used to meet multiple states’ requirements. Yet DEQ is also cautious.

“I think we're reticent that the call for harmonization on that front be kind of a veiled call for a race to the bottom,” Portley said.

DEQ takes responsible end markets very seriously, in part because they are pivotal in the the origin story of Oregon's law, Portley said.

Oregonians value the state’s leadership in recycling, she said, so the realization in the 2010s that waste collected for recycling was sometimes ending up abroad or being burned “was a big blow to the public trust in the system,” she said. “The law endeavors to repair that trust.”

On responsible end markets, draft rules in California and adopted rules in Oregon have similarities, Portley said, whereas Colorado is more sparse on this issue. “I think they left a lot of the responsible end market implementation to the program plan,” Portley said.

The idea of harmonization becomes trickier when “the extent to which states emphasize that policy lever differ from one another,” she said. Each law is particular, reflecting different state-specific priorities. Portley does still see potential for states to align definitions for producers and covered products. Logistically, though, some types of harmonization might require statutory changes.

Maine opted to pass a law in 2025 clarifying definitions for producers and other aspects of its 2021 packaging EPR law. And Maine’s Department of Environmental Protection “aligned the majority of proposed packaging material types with the producer reporting categories used in the Colorado and Oregon programs,” per a September update.

In Oregon, state regulators don’t want to decide on harmonization-inspired changes too quickly. “I think we need some time to see how these different approaches in the different states pan out. We need some evidence from implementation,” which most states haven’t yet begun, Portley noted.

“I think we’re glad that there has not been statutory change in the four years of startup that went into the start date, so that we were able to kind of stick with the plan,” Portley said. The next opportunity to revisit would likely be in 2027, Portley said.

Ameripen’s Waterfield also noted that greater data and lessons from CAA will be especially helpful for legislators considering future programs, as lawmakers in the U.S. previously relied on data from programs in Europe and Canada, where infrastructure and other factors were very different.

“The ultimate path to harmonization in the U.S. is federal legislation,” Portley said. “If producers are really wanting something fully harmonized, they may have to go that route, but it's probably not a fast route.” No such bill has been introduced.

Extended producer responsibility for packaging programs require a heavy lift to move from law to implemented program. State agencies, consultants and other groups are hiring to meet the demand in 2026 and beyond – though there can be strong competition for a limited pool of applicants with expertise. 

The programs, which have been adopted in seven U.S. states, have a complex implementation period. Some programs, such as Maine’s, left much to be hashed out during that rulemaking process. Others, like Colorado, had a more prescriptive law. 

States staff up

Wolf Kray, materials management unit leader at the Colorado Department of Public Health & Environment, said via email that appropriate staffing is essential to ensure “there are adequate resources available to successfully navigate the many complex issues associated with developing and implementing a producer responsibility program at the state level.” 

In Colorado, HB 22-1355 authorized the department to add one full-time employee in 2022 to oversee and administer the program, and one more full-time employee in 2025 to oversee compliance and enforcement.

Looking to the newest state to adopt packaging EPR, Kara Steward, Recycling Market Development Center coordinator for the Washington Department of Ecology, has been dealing with an extra wrinkle: a hiring freeze. The state is currently facing a budget deficit, and any new hires require special permission. Two employees from other programs have been pulled in to get the program started, and Steward is one of them. 

“We had to start the program and grab from people who had jobs to help out. That’s sort of where we’re at,” Steward said. “I have a full-time job doing other things … It worked out okay, but it does put some program work to the side for a short period of time until we can hire and train someone up.” 

The packaging EPR program did get permission to hire one full-time position, which it was in the process of filling at the end of 2025, but “absent the hiring freeze, we would have put out those announcements earlier,” Steward added. 

The department estimated that program implementation would need between three and eight staff positions. Steward said three of those are intended to be permanent, “from start to forever,” while the other roles are more for the first several years of implementation. An additional one or two hires in the next six months is the goal, and the department is waiting for permission from the head of the agency to do so. 

For the current employees filling in, Steward said it’s been helpful to be the youngest program, as “there are six other great states who have tested the water ahead of us.” 

In particular, looking at how other states have formed advisory boards and what those boards have covered in the first year has been useful. 

Similarly to other states, the eventual producer responsibility organization will reimburse Washington for program start-up costs, then take over funding obligations, but in the meantime, “it's a real challenge for the state to cover those first couple of years,” Steward said. The state will choose a PRO by March.

In California, CalRecycle plans to add 62 permanent staff over six fiscal years. Hiring started in the 2022-2023 budget cycle. 

“CalRecycle has hired the majority of the staff, including scientists, analysts, administrators, legal staff, and managers to help carry out research, coordinate with program participants, and ensure the program meets the law’s ambitious goals and deadlines,” an agency spokesperson said over email. 

Mallory Anderson, packaging EPR coordinator for the Minnesota Pollution Control Agency, said their program has 2.5 full-time employees assigned to administer the Packaging Waste and Cost Reduction Act, but that could increase in coming years if needed. 

“This currently involves support for program oversight, data management, advisory board support and completing the needs assessment,” she said. “The program is currently in the data-gathering phase and has not yet moved into full implementation. The agency will continue to assess staffing needs as the program evolves.” 

Agencies in the other packaging EPR states — Maine, Oregon and Maryland — did not respond to requests for comment.

Producers look for help

On the producer side, that help is also in high demand from PRO Circular Action Alliance — which was on a major hiring spree in 2025 — as well as law firms, consultants and brands.

Consultant Michael Washburn co-founded EPR Academy, which provides online classes on EPR basics and compliance. Washburn said there’s currently “stiff competition for a limited pool” of people who are well-versed in EPR. “There just isn't enough of a bench.” 

Producers in Oregon, where the EPR program is active, have started to receive non-compliance notices, Washburn said, which is driving demand as the fines could range into the millions. 

Brands are also looking to hire compliance managers, he said, with the growing recognition that EPR compliance means more than collecting and submitting data a few times per year. 

“People focus on this as a data exercise, which is absolutely true, but it's incomplete,” Washburn said, pointing to the learning, scoping, relationship building, budgeting and internal and external communication that’s needed. “There are demands being placed on enterprises for which they do not currently have capacity and do not have knowledge.” 

He said he’s heard the same from others in the field and has also seen a proliferation of tools marketed to companies to help with the data side of things.

“That’s great, but you can’t use a data widget if you don't have a data owner, if you don't have a compliance manager, if you don't have the internal infrastructure to look at this in a holistic way,” he said. “And that’s all just to get to basic compliance, let alone thinking about it as a strategic opportunity.” 

More training is needed to create a workforce with the “nuanced specialized knowledge that’s required to interpret these regulations, support producer compliance, support implementation,” Washburn said, adding that he could see business schools adding EPR classes or even minor tracks in the near future. 

On the producer side, multiple trade groups said they did not have a sense of how and if brand companies were staffing up in response. 

Washburn said a communication problem he sees often is that larger companies don’t have strong – or sometimes any – knowledge sharing about EPR compliance between branches. 

“You would think there would be an advantage to the global companies because they've been doing this elsewhere but it's not true,” he said. 

Artificial intelligence tools could be helpful; Washburn said his team uses AI to help match packaging to covered material lists. But they’re also not specifically trained for EPR and could introduce serious, and expensive, errors, he warned. 

“To get to a place where AI is a big part of the solution we have to do the first things first,” he said, “which is to have a much larger cadre of trained experts, even to go out and build and teach the tools.”

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By Specright

As Extended Producer Responsibility (EPR) programs move from policy to practice, packaging teams are starting to see what compliance really entails. Early programs are surfacing lessons that go well beyond regulatory interpretation and into the realities of how packaging work actually gets done.

What many teams are finding is that EPR isn’t primarily a sustainability challenge. It’s an operational one. And in working through early requirements, packaging teams are uncovering long-standing gaps in data, processes, and coordination that were easy to live with before compliance deadlines arrived.

Implementation Is Moving Faster Than Many Teams Expected

Several U.S. states have passed packaging EPR legislation in recent years, with Oregon already live and others, including Colorado, California, Maine, and Minnesota, close behind. For many companies, timelines feel compressed. Requirements are coming into focus at the same time teams are being asked to act on them.

For packaging teams, that speed matters. EPR isn’t something that can be addressed once a year or delegated at the last minute. Early programs are showing that compliance requires ongoing attention and a level of readiness many organizations didn’t realize they lacked.

Data, Not Reporting, Is Where Teams Are Getting Stuck

In practice, reporting is rarely the hardest part of EPR. The real work happens earlier, when teams try to assemble the data needed to support it.

In many organizations, packaging information still lives in too many places. Some data sits in spreadsheets or shared drives. Some come from suppliers via email. Other pieces exist in legacy systems that weren’t built for regulatory reporting. Even when information exists, it’s often incomplete, inconsistent, or difficult to validate.

EPR brings that fragmentation into sharp focus. When teams are asked to report on material composition, weights, formats, and volumes by state, assumptions stop holding up. Manual workarounds become the norm, and reporting turns into a scramble rather than a process.

Packaging Teams Are Becoming the Point of Coordination

Another thing early EPR programs are making clear is who ends up doing the work. While sustainability or legal teams may interpret regulations, packaging teams are typically responsible for producing the data behind them.

That has meant more time spent tracking down missing information, reconciling differences between design and procurement, and answering follow-up questions from finance teams and producer responsibility organizations. These new responsibilities haven’t replaced existing priorities like launches or supplier changes. They’ve been added on top.

For many teams, EPR is exposing a mismatch between accountability and infrastructure. Processes that were sufficient for internal use aren’t holding up when data needs to be defensible outside the organization.

The Shift From One-Time Submissions to Ongoing Work

Teams that are navigating early EPR programs with less friction tend to approach them differently. Instead of treating EPR as a standalone compliance task, they’re folding it into how packaging data is managed more broadly.

In response, some packaging teams are taking a more proactive approach to EPR readiness, focusing on aligning data structures and expectations across internal teams and suppliers earlier in the process, rather than reacting to each new state requirement as it emerges.

That often means stepping away from state-by-state spreadsheets and focusing instead on consistency. How data is captured. When it’s validated. Who “owns” it. And how it gets maintained over time. The goal isn’t just to submit a report, but to make the next one easier.

That kind of shift takes effort up front, but it pays off as programs expand and requirements change, which early EPR efforts suggest they will.

Transparency Is Becoming Harder to Avoid

Early EPR programs are also raising expectations around transparency. The data companies submit doesn’t just determine fees. It feeds into broader decisions about recycling systems, program funding, and oversight.

When data is inconsistent or poorly supported, the risks go beyond administrative headaches. Teams are increasingly aware of the potential for penalties, operational disruption, and reputational impact. As a result, conversations about data ownership and supplier accountability are becoming harder to postpone.

What These Early Lessons Point To

Taken together, early EPR programs are sending a clear signal. Compliance isn’t being won by teams with the strongest sustainability messaging, but by those with the most reliable packaging data and repeatable processes.

For packaging teams, EPR is acting as a forcing function. It’s accelerating decisions about data ownership, supplier accountability, and how packaging information is managed day to day.

As more states move from legislation to execution, those early lessons will matter even more. The question isn’t whether EPR applies. It’s whether packaging operations are set up to support it.

Stress levels are high for CPG companies and packaging groups as extended producer responsibility programs unfold in multiple states.

This was on display at three Boston events hosted by the Sustainable Packaging Coalition, How2Recycle and the Northeast Recycling Council, with questions flying about costs, policy harmonization and relationships with regulators.

Paul Nowak, executive director of GreenBlue, adopted the role of support group leader for a room full of representatives from many of the world’s largest CPG companies in his opening talk at SPC Advance. He reminded them that “you are not alone” and urged them to take the long view on this major industry shift.

“What you see at the end of the change is not what you see during the change,” said Nowak, drawing on examples from prior industry shifts as well as other major life events. “You are in this uncomfortable period right now where it's not moving as rapidly as you would think and you don't have the historic perspective yet of where it could go.” 

Sticker shock

While CPGs are familiar with EPR costs from programs in other countries, the complexity and scale of the U.S. rollout in seven states is presenting its own unique challenges.

Oregon is the only state that’s begun collecting fees, and already the costs are high. Circular Action Alliance, the producer responsibility organization selected for the majority of state programs to date, estimates a budget of $188 million in the program’s first year, with that figure growing in the years ahead. 

Charlie Schwarze, board chair for CAA and senior director of packaging stewardship at Keurig Dr Pepper, said the costs are starting to resonate with major companies. KDP, for example, has been working to sort out different aspects of its packaging in terms of licensing arrangements, private label manufacturing partnerships and other factors. This requires a close relationship with the company’s finance, R&D and procurement teams to gather data and make cost projections.

“It's been a bit of a slow-moving process because the dollars, at least in 2025, are not extremely notable. But they're going to get bigger pretty quickly,” he said, citing Colorado and California’s programs on the horizon.

Shane Buckingham, chief of staff at CAA, said it will be months until companies have a better sense of the true costs. The group set initial fees for California, which won’t be invoiced until August 2026, but those fee levels are expected to change once SB 54 regulations are finalized.

“Please don't take our early fee schedule of being indicative of what your cost will be in 2027, it's just a drop in the bucket,” he said. "The fees are going to go up significantly in California because we have to fund a $500 million [plastic] mitigation fund, we're going to have system funding to improve recycling, source reduction, reuse, refill.”

SPC Director Olga Kachook encouraged attendees to think about these fees as motivation to innovate rather than a burden. In her view, avoided fees through ecomodulation could be viewed as “possible new investment capital” for covering the costs of material switches, R&D, MRF testing, consumer education campaigns and more.

“We can innovate to those lower fees by switching to incentivized materials and formats and then we can reinvest the savings back into sustainable materials and infrastructure that seemed out of reach,” she said.

Searching for harmony

All three events also featured ample discussion about if or how aspects of current EPR programs could be better aligned. While regulators are working to align certain definitions where possible, they also noted that certain state programs were uniquely designed for a reason.

David Allaway, senior policy analyst at the Oregon Department of Environmental Quality, said during NERC’s Rethink Resource Use Conference that he sees a potential benefit to harmonizing ecomodulation approaches in some cases. But at the same time, he said, “I fear that the push for harmonization will lead to a race to the bottom” by potentially limiting the ability for states to craft policies based on their respective needs.

As for those who critique other unique aspects of Oregon’s law, such as responsible end market requirements, Allaway said “that’s not negotiable for us,” as market issues were a leading motivation for the law in the first place.

Allaway said Oregon’s system was established based on specific regional priorities, such as putting an end to exporting certain types of material that led to dumping in other countries. The state’s approach to ecomodulation and life cycle analysis is also informed by years of work on greenhouse gas inventories and consumption-based accounting, which challenges many commonly held assumptions about recyclability.

Each state has its own unique factors in terms of collection access and market infrastructure. Colorado, for example, has many areas that will be getting recycling service for the first time. Maine also has many rural areas that previously had access to recycling but lost it in recent years. Meanwhile, in Maryland, collection service may be more common but local end markets are lacking for certain commodities.

Jason Bergquist, vice president of consulting firm RecycleMe, said during the NERC event that he hears concerns from clients about where this is all headed.

“If we get to a couple years down the road and we’ve got, let’s just pretend, 25 states with EPR, with different deadlines, different [covered material] lists, different definitions, different ecomodulation — my concern as a fan of EPR is that the pushback will be so significant that it could get existential for the producers,” he said, in terms of costs and compliance management.

At the same time, Bergquist said the experiences of packaging EPR in Europe and Canada show it may take years to get toward any kind of harmonized system.

Back at SPC Advance and the co-located How2Recycle Summit, California loomed large throughout the week when it came to these questions.

Karen Kayfetz, chief of CalRecycle’s product stewardship branch, said regulators from different EPR states try to talk to one another as much as possible but in some cases they’re limited by the statutes that created these programs.

“We each have our own legal frameworks we have to work within,” she said. “So harmonization starts with the legislatures, and that is not our responsibility, but it is something that we could see change and evolve over the coming years.”

As all of these complex questions get worked out, Kayfetz reminded attendees that CalRecycle may currently be “the face” of the program but that’s not the long-term goal.

“What would make me the happiest is if you leave here thinking ‘let’s go talk more to CAA.’ Because EPR is a policy mechanism that is meant to be a public-private partnership where the public entity ... is overseeing the PRO,” she said. “They are your partner and we are their police.”

In a separate session, CAA’s Buckingham described the work of ramping up different state fee and reporting programs as building a plane while flying it. The group is working to streamline its own reporting processes as much as possible, but they and others anticipate things will only get more complicated in the near term.

“2026 will bring with it a new set of EPR laws and recycled content laws,” predicted KDP’s Schwarze, “and they're going to be different than what we have right now.”

A new coalition of packaging suppliers, brands, retailers and technology providers has created an open-source template to ease the minimum data reporting process for extended producer responsibility laws.

The Sustainable Packaging Data Council features representation from across the value chain, with a list of founding members that includes Specright, Lorax EPI, Sonoco, Atlantic Packaging, Tyson Foods and Costco. Private-label retailers were among those particularly engaged because they have “probably the most complex channel of data gathering,” said Specright Executive Chairman Matthew Wright.

The council, which formed early in 2025, recently launched a free template for reporting in Oregon and plans to develop future templates for other EPR regulations in the U.S.

2025 marks the first time producers had to assess and report supply data in the U.S. to comply with current and forthcoming state packaging EPR laws.

The council’s goal is not to monetize the templates, but “to simplify the tremendous amount of redundant data-gathering the companies are doing, or wrong data-gathering,” said Wright. “The intention of this is to enable companies do great things instead of chasing data.”

Council members say their work fills a gap that is not covered by agencies, associations or producer responsibility organization Circular Action Alliance, which is more focused on meeting states’ needs. “Ours is trying to simplify the data needs for the industry,” Wright said.

State laws spell out covered material categories, but don’t necessarily clarify how that’s interpreted into data points. “It wasn't that we needed more information to read or understand. It was really: What's the data need?” Wright said.

Katie Krasts, senior product manager at Specright, elaborated on this. “Some entities, some producers, were asking for too much data, and some were asking for too little data,” she said.

Initially there were some intellectual property-related concerns and hesitation around data-sharing. “One of the challenges was [paring down a] minimum viable list” so suppliers that were reluctant to share more detailed material data became comfortable, Krasts said. “I think that we were able to achieve that in the end.”

The partners hope the tool helps make reporters more confident. “EPR is so new in the U.S., and it's an add-on responsibility,” said Krasts. “Hopefully this is just something that will be able to give them peace of mind that they're doing what they need to do.”

The Environmental Research & Education Foundation released a report calling for more data and research to assess how extended producer responsibility programs around the world are achieving environmental and financial targets.

Research centered on specific EPR programs shows the policies generally improve recycling rates and divert material from disposal. However, “inconsistencies in reporting, a lack of baseline data, and limited transparency from [producer responsibility organizations] make it difficult to evaluate” how particular EPR programs compare with each other.

“The industry needs data, not assumptions, to guide investments and operations,” said EREF CEO Bryan Staley in a statement. “What this review makes clear is that better measurement, more transparency, and region-specific strategies are essential to understanding EPR and its ability to drive meaningful operational change.”

EPR isn’t a new concept, particularly in places like Europe. Yet adoption of such programs has accelerated around the world in recent years, especially for packaging, electronics and batteries, EREF’s literature review shows. There are now more than 400 EPR programs around the world, and about three quarters of those launched after 2001. 

Despite the growing adoption, it can be tough to pinpoint exact measures of success because EPR programs vary widely, making them difficult to compare, EREF said

Major differences include the types of materials accepted in each program and the design of the recycling systems where those materials are recycled, the report stated. Some states or regions also grapple with a lack of recycling infrastructure, consumer confusion about EPR rules, or lack of funding to maintain such programs, which further complicates assessments, the report said.

Each EPR program also has a different model for how involved producers and producer responsibility organizations are in ensuring those materials are taken care of at end of life.

The report underscores the need for more granular data, but it doesn’t cast doubt on the effectiveness of EPR as a whole. 

“While EPR is a promising tool for advancing circular economy goals, its success depends heavily on region-specific strategies, adequate infrastructure, and access to reliable performance data,” the report said. “Until those gaps are addressed, EPR’s true impact on circularity and operations will remain uncertain.” 

Numerous case studies show that EPR programs in North America and internationally have improved recycling rates and reduced landfill usage, EREF said. This is particularly true for “unique or hard-to-recycle materials” like car batteries, certain electronics and mattresses.

“However, data may not fully isolate EPR impacts from other measures or factors like recycling system maturity, market trends, and cultural dynamics,” the report states. “In addition, studies often have different methodologies, specifically pertaining to recycling rate definitions, leading to challenges when comparing data.”

Insight from individual reports can still offer clues about what’s working and what needs to be updated in particular programs, the report said. Such reports “show significantly higher recycling rates due to EPR” in countries that have had such programs for a longer time, such as Belgium, Canada, and Spain.

Belgium has one of the highest global recycling rates for packaging and printed paper. It adopted its EPR legislation in 1994 and implemented it in 1997. Germany also increased its packaging and printed paper recycling rate, from 38% to 76%, after implementing EPR in 1991, EREF said, citing a 2021 report from Eunomia.

In the European Union, new regulations on packaging and packaging waste will likely drive further recycling improvements and EPR scrutiny, the report said. 

EPR in the United States is further behind its European and Canadian counterparts, but future research could also shed light on the effectiveness of some of the U.S.’ newest EPR programs. EREF calls for U.S.-based EPR research and data to account for hurdles, including “lack of universal recycling access, low recycling participation rates, and gaps in infrastructure.” 

Seven states have adopted EPR for packaging laws in the last few years, but only Oregon’s has fully launched so far. Oregon’s program has only been in effect since July 2025. Meanwhile, other states are rolling out packaging EPR implementation plans over the next few years.