EPR anxiety: CPGs and regulators prepare for generational policy shift

Cole Rosengren • October 15, 2025

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 recent 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.”


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By Cole Rosengren | WasteDrive April 29, 2026
A combination of EPA and USDA funding has resulted in numerous changes throughout the city, including free commercial recycling service, residential recycling carts and organics infrastructure. Providence, Rhode Island, is starting to see tangible results from multiple organics and recycling programs funded by federal grants. This work was spurred by $3.34 million from the U.S. EPA’s Solid Waste Infrastructure for Recycling grant program awarded in 2023, as well as $255,850 from a U.S. Department of Agriculture grant awarded in 2024. Now, multiple years in, the city has funded new vehicles, carts and other infrastructure. Back in November 2023, Mayor Brett Smiley described the EPA funding as a big opportunity to advance sustainability efforts. “By helping divert food waste, in particular, from the waste stream we can extend the life of our Central Landfill, but also help meet our climate justice goals,” he said at a November 2023 Northeast Recycling Council event. Smiley noted this would also help address recycling issues. “We know that we’ve got a major education gap to fill with residents and business owners. The recycling rates in the city of Providence are quite low [and] there’s a very clear equity gap in terms of which neighborhoods recycle and how.” Commercial recycling One unique aspect of Providence’s grant-funded programs is free commercial recycling service, which is still coming to fruition. In his NERC speech, Mayor Smiley noted this idea was driven in part by “a problem with overflowing dumpsters” that “degrades the quality of life” in certain commercial areas with a lot of restaurants. The SWIFR grant, which has funding until January 2027, helped fund the purchase of a rearload recycling collection truck for approximately $200,000. This truck is run by the city’s Department of Public Works and initially focused on offering free service in two neighborhoods. Federal Hill and the West End were chosen for their high density and proliferation of restaurants. Participants can receive two to three carts, which will be collected twice per week. The Center for EcoTechnology is helping manage the outreach and technical assistance for this as well as a separate technical assistance program for commercial organics. Kevin Proft, Providence’s deputy director of sustainability, said in a recent interview there was a long lead time to procure the truck and progress has been slower than hoped. The city’s goal was to recruit up to 75 businesses, but so far about 10 had signed on as of early April. This is yielding an estimated half a ton to 1 ton per week. “Surprisingly, we haven’t been able to get businesses to jump at the opportunity as easily as we thought we would,” said Proft, adding the pitch is “it could potentially reduce your hauling costs by reducing the amount of waste in your dumpster.” Lorenzo Macaluso, chief growth officer for CET, said his team is working to create testimonials of participating businesses and plans to continue expanding outreach. The city is also looking at potentially expanding the program to include other neighborhoods. “Sometimes selling a free thing is harder than you think ... what we find is decision makers often need to hear things more than once,” he said. Macaluso also noted some businesses may feel recycling creates extra work, even when technical assistance is available to help with bin setup and signage. “So we’re trying to compress that learning curve as much as possible and give them those tools, but that perception is hard to overcome.” Residential recycling Providence has an estimated 2.4% recycling rate and 47% contamination rate , despite prior goals to reach 30% by 2020 as well as “eliminate contaminated recycling” by 2030 . The city recently began rolling out 55,000 new curbside recycling carts , along with an updated citywide education campaign, in an effort to reverse these trends. This came together with $1.8 million of EPA SWIFR funding, $625,000 from The Recycling Partnership and $5 million in financing from Closed Loop Partners’ Catalytic Capital & Private Credit Group. That latter commitment was backed by American Beverage’s Every Bottle Back initiative. The carts align with a new curbside collection contract awarded to WM last summer. That contract included an amendment stipulating the company pay $50,000 for recycling education in the first year and offer services at that value in the following years. A WM spokesperson confirmed that education funding is managed by the city. Another new aspect of this contract was the inclusion of WM’s Smart Truck camera technology in collection vehicles. This allows for targeted contamination monitoring and education feedback. Keefe Harrison, CEO of The Recycling Partnership, said during a recent interview this would allow for more targeted education efforts and reduce some of the need for manual cart checks or tagging. “We will be able to use cameras in the trucks to identify households that are doing a great job recycling versus the ones that are having a harder time, and then target those ‘oops’ tags for the ones that are having the harder time.” WM confirmed this is the first deployment of its technology in New England, following prior launches in other parts of the country . Proft said data reliability has been inconsistent for certain routes, but was optimistic about its long-term potential. “The sensors are a little bit sensitive and they’ve been breaking ... there seems to be a myriad reasons that we’re struggling to really get that running smoothly,” he said, while noting that “even the data we’re getting now is useful based on the capacity.” “WM is happy to be deploying this new technology in the City of Providence. With any new program there will be an implementation period, but we are pleased with the process so far and are excited about its future,” said Garrett Trierweiler, a regional director of public affairs for WM, via email. Organics In 2019, the city set a goal to “eliminate food waste” by 2040 . The recent federal funding has been used to help boost processing infrastructure, collection and education. Providence dedicated approximately $200,000 of SWIFR funding to support Groundwork Rhode Island’s West End Compost Hub. The site, an in-vessel composting project, is currently under construction and could open later this summer, according to Groundwork. USDA funding also helped cover five new organics drop-off sites managed by Groundwork, raising its total network to 16 sites . On the commercial side, SWIFR funding helped purchase two trucks for Remix Organics, a hauler in the city. This included a unique vacuum truck to collect brewery wastewater, which had become a concern for state regulators due to how it was previously managed. “They had more more customers asking for their service than they could service,” said Proft, describing this as an opportunity to “help our local economy by supporting this local business and also diverting more food waste from the landfill through these big chunks of commercial businesses.” Additionally, USDA funding covered a contract for CET to conduct outreach and education to businesses about organics recycling. This helped line up customers with vendors such as Remix and start collection service at a notable new location, the Rhode Island Convention Center. Other areas covered by the USDA grant included education that led an estimated 350 new households to participate in subscription pickups or free dropoff sites, as well as mentorship for setting up backyard composting at about 60 households. The grant also helped the Rhode Island School Recycling project set up food recovery and organics recycling at multiple elementary schools. Read article on Waste Dive.
By Marissa Heffernan | Packaging Dive April 21, 2026
The Northeast Recycling Council’s PCR Material Demand Hub centralizes resources to help packaging developers and buyers. Dive Brief: The Northeast Recycling Council launched a PCR Material Demand Hub to help companies, whether they make packaging or just purchase it, tap into domestic recycled content markets. The hub includes information on numerous materials commonly used in packaging, including paper, plastic and aluminum. While the main focus is recycled content, there’s also information on waste diversion, reuse, carbon impacts and other life cycle assessment variables. NERC hopes to add to it in the future, including resources for creating contracts. For those newer to PCR purchasing, the hub has a road map for getting started, as well as a Q&A on how to identify and buy plastic products with PCR. The hub draws on work from the Association of Plastic Recyclers in that area. Dive Insight: Companies and organizations looking to buy postconsumer recycled content and help shore up faltering domestic recycling markets have a new place to go for support. The Northeast Recycling Council launched the PCR Material Demand Hub to help counteract the recent strain on recycling markets as some brands loosen recycled content goals and resin imports surge . Megan Schulz-Fontes, executive director of the Northeast Recycling Council, said it’s the latest iteration of past programs. “We wanted to create a hub which pools all the resources that NERC had developed historically, as well as new ones that have come about since, to make it easier for organizations, whether they’re private or public, to purchase sustainable materials,” she said. In the past, NERC had worked with APR on the Government Recycling Demand Champions Program, which focused on getting governments, nonprofits and academic institutions to buy recycled materials. By 2022, activity in that program had started to lapse, Schulz-Fontes said. “We had done a lot of outreach. It was my impression that it wasn’t a need as much anymore, because those organizations had established sustainable procurement programs,” she said. However, markets shifted, most notably for PET, and today, we all “see and feel the impacts of processor closures due to the cheaper imports coming in and the chronic oversupply of virgin,” Schulz-Fontes said. There was a need again. As APR relaunched and redesigned the Recycling Demand Champions program and the National Stewardship Action Council started its “Remade in America” pledge, Schulz-Fontes said NERC wanted to support those programs and also reinvigorate some of its own. The Demand Champions Program suggests that organizations commit to PCR use, establish long-term supply agreements and think outside the box by using PCR in non-standard formats. To support those goals, the hub has a directory of manufacturers, vendors and suppliers of a variety of products with recycled content, as well as a Recycled Content and Environmentally Preferable Purchasing Directory with all levels of governmental resources, purchasing specifications and certification standards. That Environmentally Preferable Purchasing Directory is based on work that former NERC Executive Director Lynn Rubinstein did to develop an environmentally preferable purchasing specifications document, which is helpful for those who are just getting started, Schulz-Fontes said. In addition, the hub will link procurement professionals and others working in adjacent roles via an Environmentally Preferable Purchasing Network listserv called EPPnet. That’s also one of NERC’s older programs that needed new life breathed into it, Schulz-Fontes said. “We’re hoping that’s something that’s useful for folks,” she said. Anyone who is working directly on procurement is welcome to reach out to be added to the group. Other directories that NERC’s hub link to are the EcoPaper Database; Intertek’s Sustainability Certification Directory; the Electronic Product Assessment Tool; SCS Global Services Certified Green Products Guide; EPA’s CPG Product Supplier Directory; and APR’s Buyers and Sellers Directory. Read the article on Packaging Dive.
By Antoinette Smith | Resource Recycling, Inc. April 15, 2026
The Northeast Recycling Council (NERC) has created a PCR Material Demand Hub to help organizations prioritize purchases of PCR content and help strengthen domestic recycling markets. The site features resources for federal, state and local government procurement, material- and product-specific resources, and certification and standards for recycled content, including: Government procurement directory for recycled content and environmentally preferable purchasing (EPP) Downloadable guides to buying products with PCR content, identifying and buying plastic products containing PCR, environmentally preferable purchasing specifications “Green” product directories from the US EPA, APR, SCS Global Services, the Environmental Paper Network and Intertek Electronics procurement tool for devices containing PCR plastic User manual for the EPA Recycled Content (ReCon) Tool and Greenhouse Gas (GHG) Equivalencies calculator The Northeastern US has been hit especially hard by recent closures of PET reclaiming capacity, with fourth-quarter 2025 recycled commodity prices in the region reaching five-year lows . Evergreen Recycling in New York and Ohio, Alpek in Pennsylvania and Phoenix Technologies in Ohio all reduced capacity, citing lackluster demand among the factors. In line with recent short-term and long-term recommendations from industry stakeholders, the Association of Plastic Recyclers (APR) Demand Champions Program outlines three distinct actions to ensure the consistent demand required to scale up the recycling industry: commit to using PCR secure long-term PCR supply agreements expand PCR adoption into non-standard formats or specify PCR in purchased goods APR owns Resource Recycling, Inc., publisher of Plastics Recycling Update. Read article on Resource Recycling.