“Proponents of the laws are intentionally trying to spread the responsibility of recycling away from the consumer and up the supply chain. Unfortunately, distributors are a part of the supply chain that has little if any control over decisions on how a product is designed or if it can or will be eventually recycled.”
— Lauren Williams Vice President of Government Relations NAW
the Environment has already approved the Circular Action Alliance as the state’s PRO for EPR. Minnesota’s Packaging Waste and Cost Reduction Act was signed into law last year. As of July 1, 2025, producers are required to join a PRO that is registered with the Minnesota Pollution Control Agency (MPCA). Washington’s Recycling Reform Act was signed into law this year. Under the law, a PRO must be selected by Jan. 1, 2026, with producers being required to register with a PRO by July 1, 2026. In California, the Plastic Pollution Prevention and Packaging Producer Responsibility Act has been in place for three years. California is currently in the formal rulemaking process to implement the law. Also, CalRecycle is currently undergoing formal rulemaking for its EPR requirements (S.B. 54 Plastic Pollution Prevention and Packaging Producer Responsibility Act Permanent Regulations Overview), which establishes the Plastic Pollution Prevention and Packaging Producer Responsibility Act. The act imposes minimum content requirements for single- use packaging and plastic foodservice ware to be achieved through an EPR program.
26 FEDA News & Views
In Colorado, the Producer Responsibility Program for Statewide Recycling Act was signed into law in 2022 by Gov. Jared Polis. To meet the Colorado reporting deadline, obligated producers must have signed the Participant Producer Agreement and the Colorado State Addendum, logged into the Producer Portal and filed their reports by July 31, 2025. It’s evident that EPR laws are evolving quickly and, as details change, foodservice equipment dealers may find themselves scrambling to catch up. While requirements vary by state and many details are still in flux, the trend is clear: Companies that sell into affected states (and particularly those using a significant amount of packaging) should pay close attention to new registration, reporting and fee structures. Taking time now to understand the exposure will help dealers avoid compliance issues and surprise costs later.
Packaging Under Pressure As states continue to introduce and pass EPR laws for
packaging, plastic and paper, more producers will have to register, report and pay fees to their PROs for the covered products. NAW continues to track and monitor state EPR legislation and is taking the position that such acts miss the target and threaten the viability of the wholesale distribution industry nationwide. In another statement on the issue, NAW said EPR laws that enact regulatory and punitive financial burdens on wholesalers and distributors are “ineffective policies ignoring the key players in any circular economy, shielding consumers and companies that would have the greatest impact on sustainability and consumer behavior.” Primarily serving the business-to-business marketplace, wholesaler distributors offer warehousing, logistics and shipping from manufacturers and producers to retailers, contractors and other businesses. As such, NAW contends they should not be classified as “producers” in EPR laws. Additionally, while NAW is supportive of the goals of circularity — the concept of reusing and recycling materials to reduce waste — the association opposes EPR laws that regulate or tax a product at the wholesaler-distributor level of the supply chain.
Distributors in the Crosshairs Supporters of EPR laws believe they help to achieve
environmental goals, such as state-mandated recycling
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