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CAA Provides Deadline Schedule for Brands Affected by EPR

John Hite of the Circular Action Alliance provides a 10,000-foot view of EPR for packaging and CAA, along with important deadlines brands need to know to meet legislation requirements.

John Hite, director, Environmental Policy & Public Affairs at Circular Action Alliance (CAA)
John Hite, director, Environmental Policy & Public Affairs at Circular Action Alliance (CAA)

EPR is a complex and constantly moving target. As a brand, what should you be doing right now to prepare for upcoming regulations? At NPE: The Plastics Show, John Hite, director, Environmental Policy & Public Affairs at Circular Action Alliance (CAA), provided a primer on EPR for Packaging, CAA, and what you need to do to meet upcoming deadlines.

For the uninitiated, under extended producer responsibility (EPR) legislation for packaging, producers of packaging, primarily brand owners, are charged fees based on the type and weight of the packaging they supply into a given market. Those fees are then used to provide funding for the end-of-life management of covered products. Currently California, Colorado, Maine, and Oregon have implemented EPR laws; Maryland has a pre-EPR program.

“EPR requires producers to comply with a statute through what’s called a producer responsibility organization, or a PRO,” Hite explained. “The PRO—you can think of it as a joint compliance organization—has several primary responsibilities looking upstream. The PRO is responsible for working with producers on reporting, helping producers categorize their packaging, and report that to the approved PRO in a given jurisdiction.


   Read related article, “SC Johnson and AMERIPEN Testify About Federal-Level EPR”


“The PRO also sets a fee schedule for producers that meets the requirements of the given state statute, and those fees are then collected from producers and used to fund the programs on the downstream end.”

He added that the PRO is also responsible for developing what’s called a program plan, which is a soup-to-nuts overview of how the PRO is going to meet the requirements of the state statute.

CAA, formed in 2022 by a group of brands and retailers, is the first and so far the only approved PRO to assist producers in the U.S. “One of the goals of CAA from the jump was to create an organization that is a representative across the U.S. that’s able to provide a single point of compliance for consumers, recognizing there are key differences between each state,” he explained. “There are differences between the recycling systems, there are differences between the statutes, but from producer perspective, we think there’s a lot of value in being able to work with a single reporting portal. There’s a lot of value in being able to work with a single entity that has a line of sight into compliance and into the programs across the different states.”


   Read this related Q&A interview with AMERIPEN, “Packaging Legislation Update and 2024 Outlook”


CAA has been chosen as the PRO for packaging EPR in California, Colorado, and Maryland, and has submitted a program plan to Oregon. To prepare brands, CAA is conducting outreach and education.

In regard to deadlines, Hite emphasized that the “first and most important element from a producer perspective is registering with CAA.” He added, “If you believe you are likely to be an obligated producer as defined under each state statute, we are asking that producers register with the organization by July 1 of this year.”

Registering is free and involves filling out a contact form so CAA can send information on compliance steps, weekly onboarding sessions, and monthly producer working groups. The working groups provide a deeper dive into the regulatory requirements in each state, some of the data work that CAA is undertaking to develop fees, and other topics. In addition, this summer, CAA will also be sending out reporting guidance to producers.

In his presentation at NPE 2024, Hite provided attendees with a QR code that directs brands to the CAA site where they can begin the EPR registration process.In his presentation at NPE 2024, Hite provided attendees with a QR code that directs brands to the CAA site where they can begin the EPR registration process.

The next key deadline is March 2025, when producers will need to report their data to CAA. Ahead of Q1-25, CAA is also developing its reporting portal in Oregon, which will be a standardized reporting portal across the states from a producer perspective.

“CAA is going to be working directly with producers to help them understand how to tabulate their data,” said Hite. “That’s why we really want to launch that process this summer to make sure we’re helping producers understand the reporting categories in each state and understand how to set up some of their own in-house systems downstream [how much material is being managed by recycling].”  PW

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