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May 2024 Newsletter

Newsletter: May 2024

The latest news regarding WEEE, e-waste, battery and packaging compliance

May 2024: Special Edition Newsletter

Upcoming USA Registration Action for Packaging Producers

U.S. Department of Agriculture (USDA) Secretary Sonny Perdue (blue/green gingham shirt and tan mask) and Senator John Cornyn (blue gingham shirt and blue bandana/mask) tour McLane Global, one of USDA’s partners in feeding rural kids in Texas and across America who have been impacted by school closures as a result of COVID-19.


 The Secretary and Senator will tour the food box packing facility and participate in a discussion with partners Baylor Collaborative on Hunger and Poverty, Charwells K12, and PepsiCo, on July 16, in Houston, TX. The tour is led by Mclane Global Chairman Denton McLane. Also attending are U.S. Congressman Daniel Reed Crenshaw, Texas Secretary of Agriculture Sid Miller, McLane Global CEO Todd Avery, Chairman Drayton McLane, Jr., and #MillionMeals partners Baylor Collaborative on Hunger and Poverty Director of Government Relations Grace Norman, PepsiCo Food for Good Director Matt Smith, and Chartwells K12 CEO Belinda Oakley. All USDA Food and Nutrition Service (FNS) programs – including the Supplemental Nutrition Assistance Program (SNAP); Special Nutrition Program for Women, Infants, and Children (WIC); and the National School Lunch and Breakfast Programs – have flexibilities and contingencies built-in to allow them to respond to on-the-ground realities in the event of a disaster or emergency situation.USDA Photo by Lance Cheung. Original public domain image from Flickr

Packaging Extended Producer Responsibility (EPR) by individual US states has become a rapidly evolving topic, with several states actively implementing or considering legislation. While many states already have other active EPR legislation, including for e-waste, batteries, mattresses, and paint, packaging EPR has become a prominent focus area.

Maine and Oregon passed packaging EPR laws, followed closely by California and Colorado. In 2024, Minnesota passed HF 3911, which details a Packaging EPR program, bringing the total to five US states with packaging EPR. Maryland and Illinois also passed packaging laws requiring a needs assessment of their recycling systems, setting the stage for potential future EPR implementation.

For the 2024 legislative session, seven states—Massachusetts, New Jersey, New York, New Hampshire, Rhode Island, Tennessee, and Washington—have packaging EPR bills under consideration. Circular Action Alliance (CAA) has emerged as a key player in EPR implementation, serving as the Producer Responsibility Organization (PRO) in California, Colorado, and Oregon. CAA’s involvement extends to Maryland, where it represents producers’ interests on the advisory board as they move forward with a needs assessment. Looking ahead, Maine is slated to begin the PRO selection process in 2025, with a selection expected by 2026.

For those states with active regulations, obligations exist for entities involved in the production, distribution, or importation of products using covered packaging materials. These producers must register in each applicable state, join a PRO by specified deadlines, or manage individual programs, ensuring compliance with recycling and packaging standards set by respective states.

Covered materials subject to regulation vary by state but typically include food service ware, paper products, and various packaging materials. The earliest compliance deadline for producers is set for 2025, with preliminary PRO registration requested by July 1, 2024, to aid in program fee development. Accerio is assisting our clients in registering with CAA and preparing for state requirements. Producers are advised to start collecting packaging data promptly to meet reporting requirements by 2025.

For producers uncertain about their obligations in California, Colorado, Oregon, Maine, and Minnesota, Accerio can provide preliminary assessments and ongoing support as producer requirements are evolving through final rulemaking processes. With EPR laws gaining traction across the US, proactive engagement and preparation are essential for producers to navigate this evolving regulatory landscape effectively.

May 2024 Newsletter Read More »

December 2022 Newsletter

Newsletter: December 2022

The latest news regarding WEEE, e-waste, battery and packaging compliance

Updated Austrian Packaging Legislation

blue bubble wrap

In January 2023, the updated packaging legislation (Verpackungsverordnung) will come into force in Austria. There are several critical changes that impact foreign producers; many already registered producers must take action to maintain compliance under the new law.

Changes include:

  • Online marketplaces are required to confirm that their sellers are properly registered
  • Foreign distance sellers must appoint an Authorized Representative for packaging
  • Producers from EU Member States who are voluntarily taking over Austrian reseller obligations must also appoint an Authorized Representative
  • Non-EU producers cannot voluntarily take over Austrian reseller packaging obligations

Any entity can be appointed as Authorized Representative; if your company doesn’t have an Austrian entity, Accerio will register you with a third-party to keep your registration compliant.

Mexico Draft EEE Packaging Labeling Standard

In August 2022, the Mexican Federal government published a draft of the Official Mexican Standard (Norma Oficial Mexicana or NOM) No. 024-SE-2022 regarding the information to be included in the packaging, instructions or manuals, and warranties of electronic and electric equipment (EEE). The Standard would apply to all new, refurbished, rebuilt, used or second hand, discontinued EEE and household electronic appliances, as well as its spare parts, accessories, and consumables that are marketed in the Mexican territory.

The Draft details the minimum required information that should be included on the packaging or containers, instruction manuals, and warranties of EEE and household appliances. The labeling must contain, among other things, details such as the company name, manufacturing location, product type, electrical characteristics, and hazardous product warning in Spanish. Further information on the format and label dimensions are expected to be included as an Annex to the Standard.

There are specific exemptions for certain types of EEE, though most EEE will require warnings when they are hazardous products. The Standard is still under discussion; contact Accerio for more information if your company places product on the market in Mexico.

Italian Packaging Labeling Requirements

In November 2022, the Italian Ministry of the Environment and Energy Security published their Environmental Labeling Guidelines to provide clarity to the upcoming requirements. All packaging being placed in the Italian market needs to have an environmental label by 1 January 2023.

The obligation is for all packaging to:

  • be appropriately labeled in accordance with the procedures laid down in the applicable UNI technical standards
  • be appropriately labeled in compliance with the decisions of the European Commission: to facilitate the collection, reuse and recycling of packaging
  • provide consumers with proper information on the final destination of packaging

The new Environmental Labeling Guidelines confirm much of the guidance already provided by Consortium CONAI. However, the guideline provides additional clarification on the allowance for digital tools and alternatives for conveying the labeling information. Please reach out to Accerio for additional information and labeling guidance.

Canadian Consultation Papers on Plastics

The Canadian Government published two consultation papers on plastic to guide development of national-level legislation. Currently, Canadian Extended Producer Responsibility laws on packaging are only implemented by a few provinces and territories, with a focus on waste ending up with household consumers. The first consultation paper proposes a federal plastics registry for producers to report on metrics like diversion, reuse, recycling, and energy recovery of plastics placed on the market in Canada. The federal government is hoping to collect data on all plastic packaging, considering a large portion of the market is not captured in provincial EPR programs.

The second consultation paper outlines plastic and compostable product labeling for primary and secondary product packaging as well as single-use and short-term plastic products to reduce confusion and increase the proper sorting of recyclable materials and organic waste. Plastic diversion outcomes are highly dependent on public knowledge of proper waste sorting, which in turn impacts the amount of contamination in certain waste streams. The primary goals of the labeling are to reach zero plastic waste by 2030 and ensure that 80% of Canadians have access to reliable recycling.

Draft legislation is expected mid-2023 and would provide additional details of the proposed labelling and registry.

December 2022 Newsletter Read More »

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