Extended Producer Responsibility (EPR) Registration deadlines are nearing for Minnesota, Colorado and California

Circular Action Alliance (CAA) is supporting producers as major Extended Producer Responsibility (EPR) deadlines draw near.

1. Minnesota Registration Deadline – July 1, 2025

Minnesota is progressing in the implementation of its Extended Producer Responsibility (EPR) framework for packaging and paper products.

Who is affected?

Producers that distribute packaging materials and paper products in Minnesota, including brand owners, importers, and distributors, are obligated to register.

Requirement

These producers must register with the Circular Action Alliance (CAA) – the official Producer Responsibility Organization (PRO) for Minnesota – by July 1, 2025.

Minnesota State Interim Addendum (MNISA)

A critical compliance document tailored to Minnesota's specific requirements, scheduled to be released in late June 2025 after consultation with stakeholders (i.e., producers, regulators, and recyclers).
This document will clarify eligible materials, reporting protocols, and fee structures applicable under the EPR law in Minnesota.

Fee Structure

a. Producers are required to pay annual fees to the Circular Action Alliance (CAA), the designated Producer Responsibility Organization (PRO) for Minnesota. These fees are structured to cover at least 90% of the costs associated with the collection, transfer, sorting, transportation, and preparation of packaging and paper products for refill, reuse, recycling, or composting by 2031.
b. The fees collected are utilized to reduce environmental and human health impacts of packaging materials, expand recycling infrastructure, and invest in public education to promote sustainable practices.
c. Timely registration ensures that producers remain compliant and avoid enforcement actions or market access restrictions in Minnesota. Failure to register may result in penalties or a ban on selling covered products in the state. Producers can access tools and registration support via the CAA Producer Portal.

2. Colorado Reporting Deadline – July 31, 2025

Colorado’s EPR law, one of the most advanced in the U.S., mandates detailed reporting obligations from producers.

Who must report?

Producers of paper and packaging products sold or distributed in Colorado.

Deadline:

Initial EPR compliance reports are due by July 31, 2025.

Contents of the Report:

1. Volume and types of packaging supplied into the market.
2. Recyclability data.
3. Material characteristics and labelling information.
4. Fee calculation based on the environmental impact of materials.

Fees Structure:

a. While initial registration with the CAA does not require a fee, producers will begin paying dues starting January 1, 2026. These dues are based on the materials produced and used, reflecting the environmental impact of the packaging materials introduced into the market.
b. The fees support the statewide recycling system, aiming to alleviate the financial burden on local governments and encourage producers to design more sustainable packaging.
c. Circular Action Alliance is hosting multiple webinars and onboarding sessions to help producers understand how to navigate the reporting tool. It also provides clarity on Colorado-specific definitions and producer categories. It also explains how submitted data influences eco-modulation fees and recycling system design.
d. Colorado's EPR program is designed to shift end-of-life management costs from municipalities to producers, thereby incentivizing sustainable packaging design. Non-compliance may lead to administrative penalties and market exclusion.

3. California SB 54: Latest EPR Developments (May 2025)

California is making significant strides in implementing Senate Bill 54 (SB 54), the Plastic Pollution Prevention and Packaging Producer Responsibility Act. This landmark legislation aims to reduce single-use plastic waste and shift the responsibility of waste management from consumers to producers.

Overview

SB 54, signed in 2022, aims to drastically reduce plastic pollution by shifting packaging waste responsibility to producers. It requires:

i. 100% recyclable or compostable packaging by 2032
ii. 65% recycling rate
iii. 25% reduction in single-use plastic sales
iv. $5 billion producer contributions over 10 years (from 2027)

Regulatory Revisions and Public Participation

On May 16, 2025, the California Department of Resources Recycling and Recovery (CalRecycle) released updated draft regulations for SB 54, initiating a new informal public comment period that runs through June 3, 2025. This follows Governor Gavin Newsom's directive in March to revise earlier proposals that were deemed too burdensome for businesses and consumers.

CAA Implementation Timeline

Circular Action Alliance (CAA) is the designated PRO.

Registration opens: August 1, 2025
Registration deadline: September 5, 2025
Reporting window: September 15 – November 15, 2025

References:

Key EPR Deadlines Ahead: Minnesota Registration & Colorado Reporting Approaching Fast
SB 54 Plastic Pollution Prevention and Packaging Producer Responsibility Act Permanent Regulations - CalRecycle Home Page