Minnesota EPR

What is Minnesota EPR packaging

Minnesota introduced an Extended Producer Responsibility system through the Packaging Waste and Cost Reduction Act (2024).

The law requires companies placing packaging, food packaging, or paper products on the Minnesota market to finance recycling and waste management systems.

The program aims to:

• Reduce packaging waste
• Improve recycling and composting infrastructure
• Increase reusable and recyclable packaging
• Shift waste management costs from municipalities to producers.

The program is overseen by the Minnesota Pollution Control Agency (MPCA).

Does this apply to e-commerce & online sales

Yes.

Minnesota EPR applies to products shipped into the state, including online and e-commerce sales.

If packaging is used to ship goods to Minnesota consumers, it may fall under the EPR requirements.

Who is the "producer" under Minnesota EPR

The producer is generally the company responsible for introducing packaging into the Minnesota market.

This may include:

1. The brand owner
2. The manufacturer
3. The importer of the product
4. In some cases, the retailer or distributor

The law uses a tiered definition to identify which company must take responsibility.

Who must register for EPR packaging in Minnesota

Companies that sell packaged goods, food packaging, or paper products in Minnesota must participate in the EPR system.

To comply, producers must:

• Join the state-approved Producer Responsibility Organization (PRO)
• Report packaging data
• Pay EPR eco-fees.

Minnesota EPR packaging registration threshold

Small producers may be exempt if they:

• Have less than $2 million in annual global revenue, or
• Sell less than 1 ton of covered packaging per year into Minnesota.

Companies exceeding these thresholds must comply with the program.

Packaging covered (and excluded)

Covered packaging

The Minnesota EPR program covers:

• Product packaging
• E-commerce shipping packaging
• Food packaging
• Paper products
• Packaging components

Packaging includes materials used to transport, protect, or market products.

Excluded packaging

Certain packaging is excluded, including:

• FDA-regulated medical products
• Hazardous materials packaging
• Certain regulated agricultural products.

Producer Responsibility Organization (PRO)

Minnesota requires producers to join a Producer Responsibility Organization (PRO).

The state approved Circular Action Alliance (CAA) as the first PRO responsible for managing the program.

The PRO will:

• Collect producer data
• Set recycling targets
• Collect eco-fees
• Fund recycling and composting systems.

EPR registration in Minnesota

Producers must register with the PRO (CAA) to comply with the law.

The first producer registration deadline was July 1, 2025.

After registration, producers must provide packaging data and participate in the stewardship program.

Authorized representative

Companies located outside the United States may need a U.S. entity or responsible party to handle compliance with the Minnesota EPR program.

What data must be reported

Producers must report data including:

• Packaging material type
• Packaging weight
• Packaging format or category
• Quantity placed on the Minnesota market.

This information is used to calculate EPR eco-fees.

First reporting period

The program will roll out gradually as the PRO develops a statewide stewardship plan and recycling system.

Key milestones include needs assessments and infrastructure development managed by the MPCA and the PRO.

EPR reporting deadlines

Important milestones include:

• July 1, 2025 – producer registration deadline
• 2026 – statewide needs assessment
• 2028 – stewardship plan finalized
• 2029–2031 – producers gradually cover most recycling system costs.

Labels & marketing claims

Minnesota EPR does not introduce a mandatory recycling logo for packaging. Producers are expected to follow standard U.S. labeling practices, including the voluntary How2Recycle label system and FTC Green Guides requirements for environmental claims.

An example of what a label looks like on packaging sold in Minnesota

This packaging shows How2Recycle labels commonly found on products sold in Minnesota. Each label identifies disposal instructions per component: the Paper Box is recyclable curbside ("Recycle if Clean & Dry"), while the Plastic Bag requires store drop-off. The Paper Card is recyclable, while the Plastic Tray is not — consumers are instructed to separate components before disposal. The How2Recycle label is a voluntary standardized system widely adopted by U.S. brands; it is not mandated by Minnesota law.

📎 Download the How2Recycle symbols:

•  PNG – best for digital use.
• SVG  - ideal for printing and scaling.

EPR eco fees & eco-modulation

Producers must pay eco-fees based on the amount and type of packaging placed on the market.

Fees may vary depending on:

• Packaging material
• Recyclability
• Environmental impact.

The system encourages companies to use more sustainable packaging designs.

Risks, penalties & common mistakes

Non-compliance may lead to significant penalties.

Violations can result in fines of up to $25,000 per day, increasing for repeated violations.

Common mistakes include:

• Not identifying the correct producer
• Missing registration deadlines
• Incorrect packaging reporting.

What e-commerce sellers should do now

Companies selling products to Minnesota should:

• Determine if they qualify as a producer
• Track packaging materials used for shipments
• Register with the PRO if required
• Prepare packaging data for reporting.

FAQ

• Is Minnesota EPR already active

Yes, the program has been adopted and is currently being implemented in phases.

• Does this apply to online sellers

Yes, if products are shipped into Minnesota with packaging.

• Is there a mandatory recycling label

No, Minnesota EPR focuses on reporting and financing recycling systems rather than mandatory packaging logos.