Minnesota's packaging EPR law is HF 3911, the Packaging Waste and Cost Reduction Act, enacted in 2024 and administered by the Minnesota Pollution Control Agency. Producers were required to register in 2025, and the supply report covering 2025 packaging data was due by May 31, 2026, the first of an annual reporting cycle, through the Circular Action Alliance. Minnesota runs on a later timeline than the early states: the producer responsibility organization's stewardship plan and the producer cost-share phase in over the following years, with producers expected to cover a rising share of program costs toward the end of the decade.
Minnesota is an early-registration, later-payment program: producers had to get into the system in 2025 and report in 2026, but the heavy cost-share obligations phase in later than in Oregon or Colorado. That sequencing means a producer can be registered and reporting in Minnesota while the fee structure is still being built. This guide covers what HF 3911 requires, who is obligated, and the timeline.
The law and the administrator
HF 3911, the Packaging Waste and Cost Reduction Act, was enacted in 2024 and is administered by the Minnesota Pollution Control Agency. It runs through a producer responsibility organization, with the Circular Action Alliance serving as the PRO, and follows the familiar register-report-pay structure on a Minnesota-specific schedule.
Who is an obligated producer
The producer is defined through a hierarchy that generally lands on the brand owner of the covered material, shifting to the importer or distributor where there is no in-state brand owner, with small producers below the thresholds exempt. Producers were required to register in 2025, so the obligated population is already identified.
The timeline
Minnesota staggers the obligations. Registration came in 2025, and the supply report covering 2025 data was due by May 31, 2026, the first of an annual reporting cycle, aligned with several other states. The producer responsibility organization's needs assessment and stewardship plan are due later in the build-out, and the producer cost-share phases in over the following years, with producers expected to cover a rising share of program costs toward the end of the decade. Confirm the current milestones with the MPCA, since the later dates are still being set.
Minnesota rewards getting registered and reporting on time even before the full fee structure lands. For the multistate picture, see the US packaging EPR compliance guide; to determine your status, see the US packaging EPR producer obligation assessment.
Primary sources
- Minnesota HF 3911 (2024), the Packaging Waste and Cost Reduction Act: Minnesota's packaging EPR law; producers registered in 2025, with the producer responsibility organization plan due later in the build-out.
- Circular Action Alliance: The producer responsibility organization designated or selected to run the program in most US packaging EPR states; producers register, report, and pay fees through it.