Extended Producer Responsibility: July 1 is the Deadline to Register

July 1 is a key date for ISEA members, who fall under EPR regulations.  These laws and regulations cover companies whose brand names are on recyclable packaging materials. While mainly retail focused, many types of items are covered, including plastic wrap of items shipped on pallets.  If your company supplies these items, your company needs to register with the Circular Action Alliance Monday, July 1.

CAA is the Producer Responsibility Organization (PRO) approved to implement EPR laws for paper and packaging in California and Colorado, and the only paper and packaging PRO that submitted a program plan in Oregon. It was formed by large, national companies, whose products are commonly found on retail shelves around the globe.

There is no cost and to register with CAA.  However, if your company meets the definition of a “producer” there will likely be compliance costs as the respective state regulations move forward.  Note – In CA, for example, the State’s Dept. of Environmental Quality is the enforcement agency for the State’s EPR regulation.

July 1 is the deadline that allows CAA to get a head count of the number of companies, who might be covered under the California, Colorado and Oregon EPR laws.

To comply with producer registration requirements in California’s, Colorado’s and Oregon’s EPR laws for paper and packaging products, covered producers must register with CAA, unless the producer qualifies for an exemption or the producer intends to submit an individual compliance plan, under applicable law.

Any company that expects to be considered a covered producer under California, Colorado, and/or Oregon’s EPR laws, and which is not otherwise exempt from registration under those laws, must complete this form as the first step in the producer registration process with CAA. 

Here are relevant links:


In California…

Here’s part of the definition of producer:

 (w) (1) “Producer” means a person who manufactures a product that uses covered material – single-use packaging that is routinely recycled, disposed of, or discarded after its contents have been used or unpackaged, and typically not refilled or otherwise reused by the producer – and who owns or is the licensee of the brand or trademark under which the product is used in a commercial enterprise, sold, offered for sale, or distributed in the state.

Here’s part of the definition of covered material:

(e) (1) “Covered material” means both of the following:

(A) Single-use packaging that is routinely recycled, disposed of, or discarded after its contents have been used or unpackaged, and typically not refilled or otherwise reused by the producer.

(C) Plastic packaging containers that are used to contain and ship products that are classified for transportation as dangerous goods or hazardous materials under Part 178 (commencing with Section 178.0) of Subchapter C of Chapter I of Subtitle B of Title 49 of the Code of Federal Regulations.

(F) Packaging used for the long-term protection or storage of a product that has a lifespan of not less than five years, as determined by the department.

Please contact me at 703-795-6064 or at dglucksman@safetyequipment.org for more information or with any questions.

Background on EPR

EPR is a policy where manufacturers, producers, and sometimes importers of products take on the responsibility to recycle their products. This concept aims to internalize the environmental costs associated with a product by making the producers responsible for the disposal, recycling, or treatment of their products at the end of their useful life.

Key features of EPR include:

Regulatory Framework Typically implemented through legislation or regulations that set specific obligations and targets for producers regarding waste management and recycling.

Waste Management: Requiring producers to manage the collection, recycling, and disposal of their products, often through funding or participating in recycling programs.

Financial Responsibility: Producers may bear the financial burden for end-of-life management activities, which can improve recycling rates.

Environmental Goals: EPR aims to reduce the environmental footprint of products by promoting reuse, recycling, and proper disposal, to reach sustainability goals.

Overall, Extended Producer Responsibility is seen as a proactive approach to environmental management, shifting the burden of waste management from taxpayers and municipalities to the producers who create the products, thereby promoting resource conservation and sustainable practices.




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