Packaging extended producer responsibility (EPR) is moving quickly from legislation to day-to-day operations in the United States. Oregon’s program has been live since July 2025, with producer funding already supporting collection sites, equipment and local recycling programs. Washington has selected its producer responsibility organization and is working through implementation. Other states are moving along their own timelines.
Europe offers a useful view of what these systems look like after they have had time to develop. Packaging EPR has been part of European waste policy for decades. The matters because the EU’s Packaging and Packaging 91TV Regulation now adds a more harmonized regulatory framework across the bloc, while the practical EPR layer still runs through national markets. Producers register country by country, work with different schemes and report packaging under rules that have developed separately over time.
For U.S. programs, that experience is useful because many of the difficult choices are still being made. Some of the most important questions are practical ones: whether the same packaging data can be reused between programs, whether producers can understand the fees they are paying, how much administration makes sense for very small volumes, and whether the system remains connected to better recycling outcomes.
Common Packaging Data is Worth Standardizing Early
A company selling the same packaged product across several EU countries can end up repeating much of the same compliance work. The underlying facts about a package may be identical: material, weight, format and number of units sold. The way those facts are registered, classified and reported can still differ from one market to another.
The EU is now trying to reduce some of that friction. PPWR requires national producer registers while also pushing registration and reporting formats toward interoperable, machine-readable standards. That is a useful signal for U.S. states that are still building their systems. States can keep their own recycling targets, fee levels and local program requirements while using the same basic language for producer identity and packaging data.
For producers, one reliable packaging dataset is easier to maintain than several versions of the same information. For regulators and PROs, common fields make submissions easier to validate and compare. Recyclers also benefit when material data can be aggregated across programs without first being translated from several different classification systems. The earlier those definitions are aligned, the easier it is to avoid legacy systems that become difficult to change later.
Fee Signals Work Best When Producers Can Understand Them
One of the strongest features of EPR is its ability to put a visible cost on packaging choices. A fee can help fund collection and recycling while also giving producers a reason to choose formats that are easier and less expensive to manage after use. Belgium’s Fost Plus, for example, publishes a 2026 rate of €0.3604 per kilogram for transparent colorless PET bottles and flasks, while transparent PET in certain other colors is €1.2568 per kilogram. The difference is large enough for a packaging team to notice and easy enough to connect to characteristics of the material.
The picture gets more complicated when several PROs operate in the same market. A review of current shows that published 2026 rates for commercial plastic in Denmark range from 1.47 to 2.59 DKK per kilogram across three directly comparable schemes, a spread of about 76 percent. Those are like-for-like published material rates, before considering minimum charges or other contract terms.
Competition between PROs can be useful, especially when it improves service or gives producers more choice. The system becomes harder to navigate when competition also creates different classifications, reporting structures and fee formulas. U.S. programs can preserve local differences while keeping the method behind producer fees easy to follow. A producer should be able to see which part of the bill reflects collection and recycling costs, which part reflects administration and which adjustments are intended to reward or discourage a packaging design.
The Fixed administrative Burden Matters Too
EPR fees are usually discussed in dollars or euros per pound or kilogram. For smaller producers, the larger cost can be the work needed to get into the system and stay there. Europe makes that visible. PPWR continues to require producers to register in each Member State where they first make packaging or packaged products available, which means businesses still have to work through when entering additional EU markets. Depending on the market and how the producer sells, the compliance process may also involve a PRO arrangement, local representation, recurring reports and supporting documentation. For a company selling small volumes into several countries, those fixed tasks can matter more than the environmental fee on the packaging itself.
U.S. programs already have examples of a more proportional approach. Oregon’s Recycling Modernization Act provides a small-producer exemption, and qualifying producers do not need to register with a PRO, report supply data or pay PRO fees. The details will naturally differ from state to state, but the principle is worth protecting. A business placing a negligible amount of packaging into a market creates a different administrative and environmental profile from a national producer placing thousands of tons.
Reasonable thresholds also help program administrators. Every producer account has to be maintained, every report has to be processed and every compliance issue has to be followed up. Bringing very small producers into the full process can consume resources that might have a greater effect elsewhere in the recycling system. If states use de minimis thresholds, greater consistency in how those thresholds are calculated would make compliance easier without changing each state’s policy goals.
Keep the System Tied to Recycling Outcomes
The most important measure of an EPR program is what happens to the material after it enters the waste stream. Oregon’s first year is already giving the U.S. industry a practical view of that transition, with producer-funded investment reaching collection infrastructure, equipment and local recycling programs. Reporting requirements can support those outcomes when the data helps plan collection, understand material flows, finance processing or identify packaging that creates problems at sorting facilities. Fee modulation can help when it reflects real differences in recyclability or system cost.
Producer registration also has a clear purpose when it creates a reliable funding base and a level playing field. The value of additional administrative requirements becomes less obvious when the information being collected cannot be connected to financing, enforcement or better waste-management decisions. As programs mature, it is worth asking what each new reporting field or classification is actually helping the system accomplish.
Europe’s experience shows how easily the compliance layer can grow as individual systems develop over many years. The U.S. has the advantage of building several programs at roughly the same time and can still coordinate the parts that do not need to be unique. Common data definitions, transparent fee logic and sensible treatment of very small producers would remove a great deal of repetitive work while leaving states free to design recycling systems around local conditions.
Packaging EPR is a financing and accountability mechanism for a physical waste system. The strongest programs will be the ones where producers understand what they are paying for, regulators can use consistent data, and recyclers see the money and incentives translate into better collection, sorting and end markets. Europe has already done much of the trial and error. U.S. programs can use that head start while there is still time to keep the administrative architecture relatively simple.