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
On January 12, 2026, before leaving office, New Jersey Governor Phil Murphy signed S.B. 1042, the “Protecting Against Forever Chemicals Act,” into law, thus adding the Garden State to the list of states that have enacted...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 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
January 1, 2026 was the effective date for a number of state law provisions relating to intentionally added PFAS in certain categories of products. July 1, 2026 will be the effective date for several more. As we have...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
Contaminants Compass is a monthly newsletter that provides updates, legal observations and actionable tips to navigate the evolving legal challenges of per- and polyfluoroalkyl substances (PFAS) and similar chemicals and...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
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
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
The Brazilian government has published Federal Decree No. 12,688/2025, regulating provisions of Federal Law No. 12,305/2010 (the “National Policy on Solid Waste”) and establishing the nationwide reverse-logistics system for...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
A new era of corporate environmental regulations is emerging through Extended Producer Responsibility (EPR) packaging legislation. While EPR laws have existed in the U.S. for years for specific products like paint,...more
Seven states have now enacted Extended Producer Responsibility (EPR) laws focused primarily on packaging: California, Colorado, Maine, Maryland, Minnesota, Oregon, and Washington. So far, five of those states have...more
On September 22, 2025, we attended Circular Action Alliance’s (CAA) Quarterly Update webinar. CAA is the Producer Responsibility Organization that has been selected by states with active plastic and packaging Extended...more
Extended Producer Responsibility (EPR) laws are now active in seven states: Maine, Oregon, California, Colorado, Minnesota, Maryland, and Washington with pending legislation in additional 11 jurisdictions. With the passage of...more
California’s Plastic Pollution Prevention and Packaging Producer Responsibility Act, also known as Senate Bill (SB) 54, continues to move forward toward full implementation with the issuance of new guidance documents....more
First effective in 2024, the Act bans the sale or distribution of various products that contain intentionally added PFAS chemicals. On January 1, 2026, as part of the product phase-out timeline, the new law bans the sale or...more
California’s Plastic Pollution Prevention and Packaging Producer Responsibility Act, SB 54, requires producers of single-use packaging and plastic food serviceware sold in California to assume financial responsibility for the...more