The Short Answer
US EPR (Extended Producer Responsibility) charges producers of packaging based on unit weight × annual volume × state rate ($/lb). Harder-to-recycle materials pay up to 10–20× more. Oregon and Colorado have been collecting since 2025; California starts August 2026. Switching to easy-to-recycle materials such as molded fiber typically cuts annual fees by 50–80%.
Which States Are Collecting?
| State | Bill | Fee Status | Earliest Fees | Small-Business Exemption |
|---|---|---|---|---|
| Oregon | SB 582 | Live — collecting | Jan 2025 | < $5M global revenue or < 1 ton |
| Colorado | HB 22-1355 | Live — collecting | Jan 2025 | < $5.5M global revenue or < 1 ton |
| California | SB 54 | Estimated rates published | Aug 2026 | < $1M in-state sales |
| Maine | LD 1541 | Rulemaking | ~Sep 2026 | < $2M global revenue or < 1 ton |
| Maryland | SB 901 | Rates TBD | 2028–2029 | < $2M global revenue or < 1 ton |
| Minnesota | HF 3911 | Rates TBD | Jan 2029 | < $2M global revenue or < 1 ton |
| Washington | SB 5284 | Rates TBD | Jan 2030 | < $5M global revenue or < 1 ton |
Note: California's exemption test uses in-state sales ($1M, the lowest); other states use global revenue. Fees are invoiced through state-approved Producer Responsibility Organizations (currently mainly Circular Action Alliance / CAA).
The Core Formula
Annual EPR Fee = Unit Weight (lb) × Annual Units × State Rate ($/lb)
Conversion: 1 g = 0.00220462 lb, i.e. weight_lb = weight_g × 0.00220462. Every state follows the same basic logic: fees scale with packaging weight, and each material category carries its own rate based on how recyclable it is — the harder to recycle, the higher the rate.
- Weight conversion — Start from the total unit weight (including lid film, labels and all components); density and design thickness directly set the cost base.
- Classification — Packaging is sorted into rate categories: recyclable plastics (PET/HDPE/PP), hard-to-recycle plastics (PS/PVC/multi-layer laminates), paper/fiber, glass, metal. The category sets the rate tier, with gaps up to 10–20×.
- California adders — CA fee = base rate + PPMF weight & component fees (~$0.05–0.09/lb + $0.18–0.23/lb) + Reuse Investment Fee (~$0.001–0.0015/lb), which is why CA shows a low/high range.
- Composites — Packaging with lidding/liner film is billed per component: the tray body at its own material rate, the lid at the flexible-film or laminate rate, then summed.
Material Rates by State (2025–2027 cycle, $/lb)
Rigid materials:
| Material | Oregon OR | Colorado CO | CA (Low) | CA (High) | Recyclability |
|---|---|---|---|---|---|
| EPS foam | 1.38 | 1.72 | 0.47 | 1.27 | Very low |
| PP polypropylene | 0.62 | 0.20 | 0.12 | 0.36 | Medium–low |
| Clear PET | 0.57 | 0.50 | 0.12 | 0.36 | Medium |
| Molded fiber (pulp) | 0.08 | 0.13 | 0.02 | 0.05 | High |
Flexible films & laminates (lidding and liner films bill at these rates):
| Material | Oregon OR | Colorado CO | CA (Low) | CA (High) | Recyclability |
|---|---|---|---|---|---|
| PP flexible film | 1.02 | 0.64 | 0.31 | 0.80 | Very low |
| Plastic laminates | 1.02 | 0.74 | 0.57 | 1.48 | Very low |
Key insight: In Oregon, EPS ($1.38/lb) costs 17× more than molded fiber ($0.08/lb); California's laminate cap ($1.48/lb) is 30× the fiber rate. Material choice outweighs weight optimization for EPR cost. Flexible films and laminates sit in the highest rate tier — exactly where recyclable mono-material (PE/PP) films and recyclable high-barrier structures create value.
Worked Example: PET Tray vs Molded Fiber
Scenario: PET tray at 28 g/unit, 750,000 units/year, compared with an equal-size molded fiber tray (~26 g body + 1.8 g lid film).
| Material | Oregon OR | Colorado CO | CA (Low) | CA (High) |
|---|---|---|---|---|
| PET annual fee | $26,389 | $23,149 | $17,104 | $32,607 |
| PET fee per tray | 3.52¢ | 3.09¢ | 2.28¢ | 4.35¢ |
| Molded fiber annual fee | $6,465 | $7,478 | $3,365 | $6,602 |
| Fiber fee per tray | 0.86¢ | 1.00¢ | 0.45¢ | 0.88¢ |
In Oregon: PET costs $26,389/year while the fiber option (body $3,429 + lid $3,036) totals $6,465 — saving $19,924 per year.
Key Takeaways for Exporters
- Classification beats weight — The rate gap (10–20×) dwarfs any lightweighting gain. Moving packaging from "hard-to-recycle plastic" into the "recyclable/fiber" category is the biggest fee lever.
- Measure early, win the client — OR and CO are already collecting; CA starts August 2026. EPR cost estimates are becoming a standard step in US packaging procurement.
- Split composite structures — Lidding and liner films bill at higher flexible-film/laminate rates. Reducing film grammage or switching to recyclable mono-material structures directly lowers fees.
- Watch eco-modulation — Multiple states plan fee discounts for recyclable/recycled-content/compostable designs, and adders for PFAS or dark materials. EPR cost is decided at the design stage.
The interactive calculator below has these rates built in — enter your packaging specs to compare annual fees and savings.