States Pass EPR Legislation; The Toy Association™ Shares Resources to Navigate Compliance

October 30, 2023 | The Toy Association™ is closely monitoring the progression of enacted Extended Producer Responsibility (EPR) laws for paper and packaging throughout the U.S., focusing on the compliance requirements for its members.

Presently, four states — Maine, Oregon, Colorado, and California — have passed legislation to establish EPR programs for paper and packaging, each in different stages of implementation. While each state law is different, most will require registration with a producer responsibility organization (PRO) so that companies may continue to sell, offer for sale, import, or distribute covered materials in that state. The Toy Association is providing members with the following resources for information on these new requirements:

Upcoming SGAC Meeting
During the upcoming State Government Affairs Committee (SGAC) meeting on November 6, participants will have the opportunity to gain insights from Reverse Logistics Group (RLG), a potential PRO in Oregon. RLG will shed light on the intricacies of EPR laws and how they may affect toy manufacturers and distributors.

RLG EPR Webinar
Members are also encouraged to register for an upcoming RLG webinar, “How to Be EPR Ready: Essential Steps to Collect and Prepare Your Packaging Data to Meet Regulatory Reporting Requirements,” taking place November 7 at 11:30 a.m. (Eastern). The session will cover where and when packaging EPR takes effect in the U.S., who will be responsible to pay fees, best practices for gathering and organizing data, and more.

CAA Obligated Producer Survey
Earlier this year, Colorado designated Circular Action Alliance (CAA) as the sole Producer Responsibility Organization (PRO) responsible for implementing its EPR law and assisting producers in fulfilling their compliance obligations. Manufacturers can participate in CAA’s survey to ensure that companies anticipating obligations in one or more states are kept informed with current information and alerts.

Completing the survey may lead to an invitation to an upcoming Producer Working Group meeting, which will be an opportunity to dive deeper on next steps in the implementation process and share perspectives on specific rule concepts under discussion within and across states. The survey also offers an option to express support for CAA's selection as the exclusive PRO in California, aiming to enhance opportunities for harmonization and maximize associated benefits for producers.

Members may contact The Toy Association’s Erin Raden, senior director of state government affairs, for more information or to become involved in the State Government Affairs Committee.