This is part of AIAG's series recapping sessions from the 2025 IMDS, Product Compliance & Sustainability Conference. Registration is now open for the 2026 conference October 7–9 in Novi, Michigan.
Extended producer responsibility is rapidly reshaping how companies manage packaging across the United States, with new state laws shifting financial and operational burdens onto producers.
During the “Packaging EPR Update” session at AIAG’s 2025 IMDS Conference, Collin Stecker and Dan Hankinson outlined the current landscape and what companies should expect next. Stecker is principal engineer, EPR/chemical regulated reporting, at Toyota, and Dan Hankinson is program manager, Mopar Global Product Regulatory Compliance, at Stellantis.
Stecker said the push for packaging EPR laws stems largely from stagnant recycling rates. “Currently, only 21% of product packaging is recycled on average at the consumer level,” he said. Even states with relatively high recycling rates, including Oregon, California, Maine, and Minnesota, are adopting EPR laws because they are “hitting the upper bound of what we can do just by interacting with consumers.”
EPR shifts responsibility for post-consumer packaging waste from individuals to producers. Stecker said it is “an environmental policy approach that takes a producer’s responsibility for their product, in this case the packaging as well, and extends it to the post-consumer stage.” Depending on the state, the goal is to shift roughly one-third to one-half of recycling system costs to producers.
Producer Responsibility Organizations and Rising Costs
Central to the framework is a producer responsibility organization, which collects packaging data and fees from companies and distributes funds to municipalities and recyclers. Circular Action Alliance is currently the only approved PRO implementing packaging EPR laws in the United States.
The financial impact is already measurable. Through an industry working group, seven original equipment manufacturers reported paying about $1.1 million to Oregon alone. “It is a sizable economic impact on the auto industry right now,” Stecker said, warning that costs will escalate as additional states adopt similar laws.
Hankinson highlighted how material choice directly affects fees. While paper fiber represents a large share of packaging weight, he noted “the fee is only 7.6 cents per pound.” Plastics, by contrast, carry significantly higher fees. “That’s a huge indicator of where we’re going to go with EPR,” he said.
Operational Lessons and Reporting Challenges
Implementation has revealed significant operational complexity. Stecker said one key lesson is to think broadly about what qualifies as reportable packaging. Beyond primary product packaging, companies must consider tertiary materials, pallets, repacking operations, protective films, labeling, and even promotional items.
“There’s a much larger umbrella of items and operations that gets caught under the scope of these EPR laws,” Stecker said. On-site reviews uncovered unexpected sources of reportable materials and opportunities for reduction. In some cases, parts had “excessive bagging,” while similar products used dramatically different packaging approaches.
Data collection has proven especially challenging. “The amount of data that is available for the packaging isn’t the same as that we would have had ready for our parts,” Stecker said. States also vary widely in reporting categories, with Oregon and Colorado using roughly 60 material categories and California requiring 95. Companies must store records for up to five years and be prepared for audits.
Advocacy has helped shape certain regulations. Stecker said multi-industry coalitions helped narrow business-to-business reporting requirements in Maine, and California withdrew an initial proposal deemed overly burdensome. Stecker stressed the importance of engaging early when states consider new legislation.
Future Obligations and What Companies Can Do Now
Looking ahead, Hankinson said companies should expect continued divergence among states. “All the different laws are fundamentally different because what are the regulators trying to accomplish?” he said. For example, Washington aims to make producers responsible for 90% of recycling costs, compared with lower targets elsewhere.
Fee modulation tied to recycled content and recyclability is also emerging. “If you use a certain amount of recycled content in your packaging, then good for you, and I’m going to charge you less,” Hankinson said. However, supply constraints and performance limitations can complicate compliance.
To prepare, Hankinson advised suppliers and manufacturers to begin gathering detailed packaging data now. “We’re going to ask you for more information on your products,” he said, including box weight, material types, and recycled content percentages.
EPR requirements are unlikely to fade. With multiple states already implementing laws and others considering them, Stecker said, “This trend, this reporting requirement, is not going to be going away.”
Learn More About EPR
To learn more about EPR, visit Circular Action Alliance’s website. CAA is the only U.S. Producer Responsibility Organization approved to implement EPR packaging programs in multiple states for paper and packaging.
SAVE THE DATE FOR THE 2026 IMDS CONFERENCE
This topic and more will be covered at the 2026 IMDS, Product Compliance & Sustainability Conference from October 7–9, 2026, at Vibe Credit Union Showplace (formerly called Suburban Collection Showplace) in Novi, Michigan. Learn about the latest sustainability topics as well as global legislative issues and IMDS topics. Conference registration is officially open, so secure your spot today.