US state EPR programs — status mid-2026
| State | Law / Program | Status | Fee mechanics |
|---|---|---|---|
| Oregon | Recycling Modernization Act | Fees active (since 2025) | Producer fees by material, eco-modulated |
| Colorado | Producer Responsibility Act | Producer dues active (since 2025) | Dues by material category |
| California | SB 54 | Fees phasing in (~2027) | Plastic-focused, source-reduction targets |
| Maine | Stewardship Program | Rulemaking | Municipal reimbursement model |
| Minnesota | Packaging Waste & Cost Reduction Act | Enacted, fees ~2029 | Phased producer responsibility |
| Washington | Recycling Reform Act | Enacted 2025, phased | Producer responsibility organisation model |
| Maryland | EPR for Packaging | Enacted 2025, phased | Program plan in development |
Rulemaking moves quarterly — treat this as an orientation map and verify current fee schedules per state before committing budgets.
UK pEPR — published base fee structure
The UK scheme publishes per-tonne base fees by material, revised annually. First-year published base fees were approximately: plastic £485/t, fibre-based composite £455/t, aluminium £435/t, wood £320/t, steel £305/t, glass £240/t, paper & board £215/t. From year two, fees are modulated by recyclability assessment (RAM) rating — red-rated formats pay more, green-rated less. The per-tonne gap between plastic and paper/board is itself a material-choice signal: track the underlying substrate economics via the fibre & board indices and polymer indices.
Germany vs France vs UK
| Market | Structure | Registration | Modulation |
|---|---|---|---|
| Germany | Competitive dual systems | ZSVR LUCID register (mandatory) | Per-system pricing by material; minimum standard for recyclability |
| France | Centralised PRO (CITEO) | CITEO declaration | Strong bonus/malus: PCR content bonuses, penalties for disruptive formats |
| UK | Single scheme administrator (pEPR) | Producer data reporting | Published base fees by material + RAM recyclability modulation from year 2 |
Eco-modulation, worked through
10,000 units of a 32 g plastic pack = 0.32 tonnes of obligated plastic. At an illustrative €500/t base fee, the batch owes €160. If the scheme grants a 10% bonus at ≥50% PCR content, a 50%-PCR pack pays €144; a 30%-PCR pack below the threshold pays the full €160. The recycled-content decision is therefore both a material-cost question — track the virgin-vs-recycled spread via PET_RESIN and RPET_FOOD — and a compliance-cost question.
Frequently asked
Which US states currently have active EPR laws for packaging?
As of mid-2026: Oregon (fees active since 2025 under the RMA program) and Colorado (producer dues since 2025) are collecting; California's SB 54 phases fees in from around 2027; Maine, Minnesota, Washington, and Maryland have enacted laws at various rulemaking stages. Programs evolve quickly — verify the current rulemaking status for each state before budgeting.
What is eco-modulation in EPR fees?
Eco-modulation adjusts a producer's base fee by design criteria: recycled (PCR) content, recyclability rating, or use of disruptive materials. Schemes such as France's CITEO grant bonuses for higher PCR content and penalties for hard-to-recycle formats; the UK's pEPR modulates by recyclability assessment (RAM) from its second year.
How do EPR fees differ between Germany, France, and the UK?
Germany runs competitive dual systems with producer registration in the ZSVR LUCID register — fees are negotiated per system and material. France centralises through CITEO with strong bonus/malus eco-modulation. The UK's pEPR uses a single scheme administrator with published per-tonne base fees by material, modulated by recyclability rating from year two.
How much can recycled content reduce EPR fees?
Illustrative model: 10,000 units × 32 g plastic = 0.32 t. At a €500/t base fee that is €160 per batch. A scheme granting a 10% PCR bonus at 50% recycled content brings it to €144; at 30% PCR with no bonus threshold met, the full €160 applies. Multiply across a portfolio and eco-modulation becomes a material cost lever — model your own SKUs with the OPN EPR cost estimator.
How can I automate EPR fee reporting from a bill of materials?
Map each SKU to a jurisdiction array (scheme, material class, per-unit weight, modulation basis) using the PackIndex EPR JSON schema, then feed it to the EPR Fee Calculator PACKIQ agent via API or MCP for quarterly reporting output across EU, UK, US state, Canadian, and Latin American schemes.
Model EPR exposure for your portfolio
The OPN EPR cost estimator and the PACKIQ EPR Fee Calculator agent map SKUs across EU, UK, US state, Canadian, and Latin American schemes — flagging the highest-exposure formats for reformulation.
EPR Cost Estimator → Circularity Agents → EPR JSON Schema →