ACI’s 2026 Extended Producer Responsibility (EPR) Think Tank conference brought together stakeholders from regulated companies, industry groups, government, producer responsibility organizations (PROs), outside counsel, and...more
Confirm producer status in every EPR state where you sell, complete state-by-state registration with the designated producer responsibility organization, and calendar near-term milestones to avoid sales prohibitions tied to...more
Welcome to the February edition of Nutter’s Environment & Energy Insights, a periodic update of current trends in environment and energy law. This month we cover: Oregon Preliminarily Enjoined from Enforcing its EPR Packaging...more
US extended producer responsibility (EPR) requirements relating to packaging are in the early stages and increasing. Legislation has been adopted in several states, with more legislation, rules and other implementing actions...more
On February 6, 2026, the U.S. District Court for the District of Oregon granted a preliminary injunction halting enforcement of Oregon's Plastic Pollution and Recycling Modernization Act against the National Association of...more
The new world of Extended Producer Responsibility (EPR) state laws may be facing big changes in the coming months. On February 6, the federal judge in National Association of Wholesaler‑Distributors v. Feldon, issued an order...more
On August 12, 2026, the new EU Packaging and Packaging Waste Regulation (“PPWR”) will be into force. Manufacturers must be prepared by then. The new Regulation (EU) No 2025/40 is part of the European Green Deal and sets the...more
Food and beverage companies are subject to extended producer responsibility (“EPR”) laws in several U.S. states. These EPR laws aim to shift responsibility for recycling and end-of-life management of packaging from states and...more
Have you heard the term “EPR” for years but thought (hoped?) it did not apply to your company's operations? Read on for an overview of the state extended producer responsibility (EPR) requirements that have been enacted in...more
Oregon's packaging Extended Producer Responsibility (EPR) law is being actively complied with by thousands of manufacturers, importers, distributors, and retailers from around the country. Those substantial compliance efforts...more
American Conference Institute (ACI)’s second extended producer responsibility (EPR) Think Tank in New York City is gaining traction as “the” leading conference for EPR packaging programs. This year’s conference, held January...more
Extended producer responsibility (EPR) laws are increasingly making companies that market, distribute, and sell packaged consumer products responsible for the cost to dispose of the packaging that they place in the market....more
Since Holland & Knight's previous alert about state extended producer responsibility (EPR) laws for packaging, there have been significant developments in the implementation of these programs. Seven states currently have EPR...more
What Happened? California - On January 9, 2026, California’s Department of Resources Recycling and Recovery (CalRecycle) withdrew its proposed regulations implementing the Plastic Pollution Prevention and Packaging...more
On January 9, 2026, the California Department of Resources Recycling and Recovery (CalRecycle) officially withdrew its proposed regulations for the Plastic Pollution and Packaging Producer Responsibility Act (SB 54) from the...more
Key Takeaways - What Happened: On December 16, 2025, the Washington Department of Ecology (Ecology) adopted a new rule – the Battery Stewardship Program, Chapter 173-905 WAC – to implement and clarify requirements under...more
Extended producer responsibility (EPR) is increasingly recognized as a core factor in transactional due diligence in the United States, with real cash costs, operational implications, and liability exposure that can...more
Effective last January 1, 2025, California’s extended producer responsibility (“EPR”) packaging and food service ware program, the Plastic Pollution Prevention and Packaging Producer Responsibility Act (the “Act" or "SB 54"),...more
Congressman Lou Correa introduced the Design for Recycling Resolution (“Resolution”) that is described as recognizing and encouraging: … efforts by manufacturers to reduce waste and consumption of raw materials by...more
Producers are required to appoint a producer responsibility organization under Washington State’s Recycling Reform Act by January 1, 2026. The Act is Washington’s extended producer responsibility (EPR) law. In this post, we...more
A Rapidly Fragmenting Regulatory Landscape - State governments have entered an era of aggressive, uncoordinated rulemaking across the food, beverage, personal care, and packaging sectors...more
States across the country are shifting the financial responsibility of managing packaging waste from local governments and consumers to the companies that place the packaging into the marketplace. These packaging Extended...more
Long known for its progressive environmental policies, Oregon once again became a frontrunner with the 2021 passage of the Plastic Pollution and Recycling Modernization Act (RMA). The RMA is a new Extended Producer...more
In today's rapidly evolving regulatory landscape, companies must stay ahead of emerging state-level environmental regulations that are reshaping the responsibilities of manufacturers, distributors, brand owners, and...more
As of October of this year, seven states have passed EPR laws (i.e., California, Colorado, Maine, Maryland, Minnesota, Oregon, and Washington), and more have bills pending in their legislatures. These laws are intended to...more