Theory Meets Reality: Packaging EPR Goes Live July 1

Chaz Miller • June 30, 2025

Recycling coordinators know that some people and locations are stubbornly indifferent to recycling. COVID has ruptured civic values and behavior. Creating a recycling culture is harder than ever. Producers know how to sell their products. Now they need to learn how to sell recycling.


On July 1, Oregon’s packaging and paper extended producer responsibility (EPR) program begins operating. This will be a first in our country. “Producers”, instead of local governments or private citizens, will be paying to recycle packages and paper products. Colorado’s program begins operating early in 2026. For years we have heard the theory of how packaging EPR will work. At last, we will get results. 

Five other states also have laws. Their programs should all be operating by 2030. None of the state laws have identical requirements. The Circular Action Alliance, the “producer responsibility organization” responsible for managing the program in most of those states, knows it has a lot on its plate.


EPR laws are not new to the U.S. Thirty-two states already have laws that cover a wide variety of products such as electronics, paint, mattresses, batteries, etc. Those laws are relatively simple. Most cover one product. The producer group is a small number of companies. Goals and programs are focused and narrow. They are a mixed bag of success and failure.


Packaging EPR is far more complex. The number of covered products is way higher. Thousands of companies are paying for these programs. Goals are challenging. Some are impossible to meet. In addition, local governments treat recycling as a normal service. Their residents will still call them if their recyclables aren’t picked up.


It probably hasn’t helped that advocates tout EPR as the solution for recycling’s problems. We are told we will have more collection and better processing with higher recycling rates. Markets will improve and even stabilize. Some of this will happen, but not all.

Collection and processing should go smoothly in Oregon. The state has high expectations for recycling. I have no doubt recycling will increase. Collection programs will blanket the state, giving more households the opportunity to recycle. 

I’m not sure, though, how much of an increase we will see. Recycling coordinators know that some people and locations are stubbornly indifferent to recycling. COVID has ruptured civic values and behavior. Creating a recycling culture is harder than ever. Producers know how to sell their products. Now they need to learn how to sell recycling. 


Another challenge is the “responsible end market” requirements. You’ve probably seen pictures of overseas dumps created by unscrupulous or just naïve plastics “recyclers”. In response, Oregon and the other states are requiring sellers and end markets to prove they are “responsible”. They must provide information about who and where they are, how they operate, how much was actually recycled, and more.


Recycling end markets pushed back. Paper and metals recyclers argue they shouldn’t be covered. They don’t cause those problems. As for plastics, the general manager of one of America’s largest plastics recycling companies said his company now spends time and money gathering data and filling out forms to prove they’re “responsible”. His virgin resin competitors don’t have to.

Ironically, we now import more plastics for recycling than we export. Maybe those countries should impose similar requirements on their plastics recyclers.


Colorado faces unique problems. The mountain state is large. Its population is concentrated on the I-25 corridor running north and south through Denver with low population density elsewhere. Recycling collection and processing is limited as are end markets. To make matters worse, slightly more than half of its households use “subscription” services for waste and recycling collection. Those services are funded by the households, not by taxpayers. EPR doesn’t have this experience in other countries. Colorado gets to blaze this trail. The second state to go live poses substantive challenges for producers.


The good news for both states? Local governments that pay for recycling collection and processing will see most of those costs go away. Consumers are unlikely to see prices rise, for now. National companies will simply spread their costs among all 50 states. Local and regional producers, unfortunately, don’t have that advantage. 

As for improved markets, remember that recyclables are and always will be commodities subject to the ups and downs of the economy. I don’t see substantive changes in recycling markets unless the producer group’s members try to manipulate markets to their own advantage.

2025 saw new laws and changes to existing laws. Maryland and Washington became the sixth and seventh packaging EPR states. At the same time, California is rewriting its regulations and Maine significantly revised its law. Some of these changes narrowed EPR’s scope to the dismay of advocates. 


I’m a member of Maryland’s EPR Advisory Council. We’ve been meeting for a year, discussing the Needs Assessment and now our new law. We have our own unique set of challenges. We also have a big advantage. We can learn from Oregon’s and Colorado’s experiences. Tune in next year to learn how we are progressing.



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By Waste Dive December 9, 2025
MRFs in the Northeast United States reported a decrease in average prices for nearly all recycled commodities — with glass and bulky rigids providing the rare bright spot — during the third quarter of 2025, according to a report from the Northeast Recycling Council. This continues the downward trend reported in the region since Q2. In Q3, average blended commodity value without residuals was $75.14, a decrease of 21.9% from the previous quarter. When calculating the value with residuals, prices were $60.16, a decrease of 27.24%, says the quarterly MRF Commodity Values Survey Report. Single-stream MRFs saw values decrease sequentially by 23.32% without residuals and 28.86% with residuals. Dual-stream or source-separated MRFs saw decreases of 17.33% without residuals and 21.76% with residuals compared to last quarter. The report includes information from 19 MRFs representing 12 states: Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont, and Virginia. The NERC report is meant to offer a regional look at price trends and is a part of the group’s ongoing work to promote and boost recycled commodity supply and demand in the Northeast. It surveys a variety of MRFs in numerous markets, including those in five states with beverage container deposit laws, which it says affect material flows into MRFs. NERC says its reports are not meant to be used as a price guide for MRF contracts because it “represents the diversity of operating conditions in these locations.” NERC adopted a new report format at the beginning of 2025 that now provides average prices for specific commodities in addition to aggregate values. According to the Q3 report, most commodity categories fell significantly, with the exception of glass and the “special case of bulky rigids.” The average price for bulky rigids in the quarter was $43.26, a 93% increase from the previous quarter. NERC did not offer insight into the increase. The average price for PET was $125.58 in the quarter, down 60%, while prices for Natural HDPE fetched about $955.31 a ton, down 46%. OCC saw an average price of about $86.23, down 10%, according to the report. Major publicly-traded waste companies echoed similar commodity trends during their Q3 earnings calls . Casella, which operates in the Northeast and mid-Atlantic, reported that its average recycled commodity revenue per ton was down 29% year over year in Q3. To reduce the impact from low commodity values, the company typically shares risk with customers by adjusting tip fees in down markets. Recent upgrades at a Connecticut MRF helped raise revenue for processing volumes in the quarter, executives said. Meanwhile, Republic Services is planning to build a polymer center for processing recycled plastic in Allentown, Pennsylvania, next year. During the Q3 earnings call in October, executives said they expect strong demand at such centers from both a pricing and volume standpoint, despite the decline in commodity prices. The company already has similar polymer centers in Indianapolis and Las Vegas, which consume curbside-collected plastics from Republic’s recycling centers and produce products such as clear, hot-wash PET flake and sorted bales of other plastics. Read on Waste Dive.
By Megan Fontes December 4, 2025
NERC’s Material Recovery Facilities (MRF) Commodity Values Survey Report for the period July - September 2025 showed a continued decline in the average commodity prices for Q3 2025. The average value of all commodities decreased by 21.90% without residuals to $75.14 and by 27.24% with residuals to $60.16, as compared to last quarter. Single stream decreased by 23.32% without residuals and 28.86% with residuals, while dual stream / source separated decreased by 17.33% without residuals and 21.76% with residuals compared to last quarter. Dual stream MRFs saw a slightly smaller decrease with residuals than single stream. Individual commodity price averages this quarter denote the decrease felt across all commodity categories apart from glass and the special case of bulky rigids.
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