NAW Position on Packaging and Paper EPR Laws
The National Association of Wholesaler-Distributors (NAW) recently updated its position on Packaging and Paper Extended Producer Responsibility (EPR) laws, highlighting the growing number of state regulations that are reshaping compliance requirements for manufacturers, distributors, and suppliers.
EPR laws shift responsibility for the end-of-life management of packaging materials from taxpayers and municipalities to the companies that produce, sell, or distribute packaged products. These programs typically require affected businesses to register with a Producer Responsibility Organization (PRO), report packaging data, and contribute to recycling and waste management costs.
Several states have already implemented or are actively rolling out packaging EPR programs, including California, Colorado, Maine, Maryland, Minnesota, and Oregon, with Washington recently joining the list. While each state’s requirements differ, the overall trend points toward increased reporting obligations, producer fees, and recycling performance expectations.
Among the latest developments:
- California finalized regulations under SB 54 in May 2026, triggering new compliance deadlines for producers.
- Maryland requires producers to register with the state’s environmental agency by July 1, 2026.
- Maine amended its packaging stewardship law in 2025, updating definitions and exempting certain products while continuing implementation efforts.
- Minnesota, Colorado, and Oregon continue advancing implementation through registration, reporting, and fee structures administered by the Circular Action Alliance (CAA).
NAW continues to advocate for clear, practical implementation timelines and regulatory consistency across states, citing concerns about compliance complexity and the burden that varying state requirements place on businesses operating in multiple markets. The association has submitted comments, sought deadline extensions where appropriate, and remains engaged with regulators and industry stakeholders as these programs evolve.
Why It Matters
As more states consider EPR legislation, distributors and manufacturers should closely monitor developments that may affect packaging, reporting obligations, and operational costs. Companies that sell products across multiple states may face an increasingly complex compliance environment as EPR programs expand nationwide.
MHEDA will continue monitoring policy developments impacting the material handling industry and provide updates as additional state requirements emerge.
Read the full update by NAW: NAW Position on Packaging and Paper EPR Laws
