Glossary

US Packaging EPR Glossary

The terms a packaging and sustainability team actually uses under the US state packaging EPR laws, defined in plain language by practitioners. For the full walk-through, see the US packaging EPR practitioner's guide.

Extended Producer Responsibility (EPR)

The principle that the company first putting packaging into a state's market funds and accounts for what happens to that packaging at end of life, including the cost of collection, sorting, and recycling. In the United States it is set state by state, not federally.

Producer

The entity a state's law makes responsible for covered packaging. It is defined through a hierarchy that usually starts at the brand owner and shifts to the importer or distributor where there is no US brand owner with a presence in the country.

Obligated Producer

The single entity that, after working a state's producer hierarchy, actually carries the registration, reporting, and fee obligations for a given product in that state. Identifying it correctly is the first task in compliance.

Brand Owner

The owner of the brand or trademark under which a product is sold. Most state EPR laws place the producer obligation on the brand owner first, before moving down the hierarchy.

Producer Hierarchy

The ordered test a state uses to find the obligated producer: typically the brand owner, then the importer, then the distributor or first seller into the state, so that exactly one entity is obligated for each product.

Producer Responsibility Organization (PRO)

A nonprofit that runs a state's packaging EPR program on behalf of obligated producers, handling registration, data collection, fee setting, and financing of the recycling system. Six of the seven state laws use this model.

Circular Action Alliance (CAA)

The producer responsibility organization designated or selected to run the packaging EPR program in most US states, which gives a multistate producer a partly common point of contact even though each state program is legally separate.

Covered Material

The packaging and, in many states, paper products that fall within a state's EPR scope and must be reported and paid on, by material type and weight. The exact scope is set state by state.

Eco-modulation

The adjustment of a producer's fee to reflect the environmental performance of its packaging, so that more recyclable packaging pays a lower rate and hard-to-recycle packaging pays more.

Producer Fee

The amount an obligated producer pays into a state's program, set by the producer responsibility organization based on the covered material the producer reports, commonly eco-modulated by recyclability.

Reimbursement Model

The approach Maine uses, in which producers reimburse municipalities for their packaging recycling costs, rather than funding a producer-run organization as in the PRO-model states. It makes Maine the structural outlier among the seven.

Needs Assessment

A study, required under several state laws, of the current recycling system and what it needs to meet the program's goals. It informs the producer responsibility organization's program plan and the fees that follow.

Responsible End Market

A market where collected recyclable material is actually used in a way that is environmentally sound. Several state laws use the concept to make sure material is genuinely recycled rather than merely collected.

Small Producer Exemption

A threshold, set by revenue or by the volume of packaging put into a state, below which a producer is exempt from some or all of the EPR obligations. The threshold differs by state.

Postconsumer Recycled Content (PCR)

Material recovered from products that consumers have used and discarded, then reincorporated into new packaging. Some state laws, such as California's, pair EPR with minimum PCR requirements.

Source Reduction

Reducing the amount or toxicity of packaging at the design stage, before it is made. Several state laws set source-reduction targets alongside the recycling obligations.

Recyclability

Whether packaging can be collected, sorted, and turned into new material in practice in a state's system. State programs use recyclability to set covered-material lists and to eco-modulate fees.

Registration

The step in which an obligated producer identifies itself to the producer responsibility organization, or the state, by the state's deadline. A producer generally may not sell covered packaging in a state without being registered.

Reporting

The periodic submission of data on the covered packaging a producer put into a state, typically by material type and weight, which the producer responsibility organization uses to calculate fees.

SB 54

California's packaging EPR law, the Plastic Pollution Prevention and Packaging Producer Responsibility Act of 2022, administered with CalRecycle and pairing EPR with source-reduction and recycling targets.

Recycling Modernization Act

Oregon's packaging EPR law, SB 582 of 2021, which introduced the producer responsibility organization model in the US and invoiced its first producer fees in July 2025.

Single-use Packaging

Packaging intended to be used once before disposal, the primary focus of US packaging EPR programs, as distinct from reusable or refillable formats.

Primary sources

The authoritative texts this guide is grounded in. Government sites may block automated access but resolve in a browser.

From terms to a mapped program

Compliance Command Center turns these concepts into a defensible, audit-ready program, run by practitioners and backed by software. It determines your obligated-producer status across each state, builds your registration readiness, and tracks the phased state deadlines against your products and packaging.

See Compliance Command Center Read the guides