Portfolio screening
Format by market, scored against current and scheduled obligations, with a failure date attached.
Capability 03 of 06PPWR · EPR fee modelling · Design for recycling
Circularity & Packaging Compliance
Packaging regulation stopped being a pledge and became an invoice. We tell you what you owe, in which market, on which SKU, and what design changes would reduce it.
- Frameworks covered
- PPWR, UK EPR, US state EPR, PFAS rules
- Typical timeline
- 4 to 10 weeks
- Unit of analysis
- SKU, market, material
- Output
- Fee model and redesign options
Definition
What is extended producer responsibility for packaging?
Extended producer responsibility, or EPR, makes the company that places packaging on a market financially responsible for collecting and recycling it. Producers register, report the weight and material of everything they supply, and pay a fee per tonne. Fees are eco-modulated, so harder-to-recycle formats cost more.
Modulated is the word that turns compliance into a design question. Two packs of identical weight can attract very different fees depending on material and recyclability. Oregon's published schedule places most paper-based materials near five cents per pound, while some plastic containers and foamed cushioning exceed one dollar thirty.
A spread that size makes design a recurring cost wherever a scheme is live. Few portfolios have been priced that way.
The rail
What is already live, and what lands next
Compliance planning treats obligations as one deadline. They arrive in sequence, across jurisdictions, on different triggers.
11 February 2025
PPWR enters into force
Regulation (EU) 2025/40 is adopted, starting an eighteen month transition.
1 July 2025
Oregon becomes the first live US scheme
SB 582 moves into implementation and producer fees become payable.
1 January 2026
Colorado fees begin
HB 22-1355 takes effect, making Colorado the second state with live fees.
30 March 2026
Commission publishes PPWR guidance
Implementation guidance and FAQs are released ahead of application.
12 August 2026
PPWR applies across the EU
Directive 94/62/EC is repealed. Restrictions on PFAS and heavy metals take effect, with design and volume efficiency rules. Empty space in e-commerce parcels is capped at forty per cent unless technically unavoidable. Conformity and traceability obligations begin.
2027
California fees expected to begin
SB 54 fees are anticipated once the programme plan is approved. Statutory penalties reach fifty thousand dollars per day.
2030
EU recyclability threshold
All packaging on the EU market must be recyclable. Member states must cut packaging waste per capita by five per cent against a 2018 baseline.
2032
California statutory targets
Sixty five per cent recycling for single-use plastic formats, and a twenty five per cent cut in single-use plastic packaging weight against a 2023 baseline.
2035 and 2040
EU reduction targets tighten
Packaging waste per capita must fall by at least ten per cent by 2035 and fifteen per cent by 2040, both against 2018.
You are here
Sources
Regulation (EU) 2025/40 as published in the Official Journal; European Commission implementation guidance, March 2026; Oregon DEQ and CalRecycle documentation. Dates reflect the position at the review date in the footer. This page is not legal advice.
What we do
Three programmes, one exposure model
Compliance work fails when it stays with the sustainability team. Ours produces numbers procurement, design and finance can act on.
01
Regulatory exposure mapping
The portfolio has to be seen before it can be fixed. We map every format against every market you sell into, then flag which combinations fail now and which fail on a known date.
Substance review
PFAS, heavy metals and restricted substances traced through inks, coatings, adhesives and barrier layers.
Labelling audit
On-pack marks and sorting instructions checked against harmonised requirements per market.
Documentation readiness
Conformity and traceability records assembled before anyone asks.
02
EPR fee modelling and eco-modulation
Fees are now a recurring line in every pack's cost. We model what you pay by SKU and market, and which design changes move it.
Fee forecasting
Projected annual liability by jurisdiction, built from your tonnage and material split.
Modulation modelling
What a substrate change saves per tonne, netted against what it costs to make and run.
Reporting readiness
Data structures that satisfy reporting without a manual rebuild every cycle.
Scenario testing
Liability under proposed rule changes, so a redesign outlives its tooling.
03
Design for recycling and claim defensibility
A pack that is technically recyclable but never collected fails regulator and shopper alike. We assess against real infrastructure, then check that what you print can be defended.
Recyclability assessment
Structures tested against design-for-recycling guidance and what local sorting captures.
Redesign routing
Mono-material, fibre-based and coating substitution compared on barrier, line fit and landed cost.
Claim substantiation
Evidence files behind recyclability, recycled content and compostability claims.
Compostability reality check
Whether a compostable format is actually collected in the market of sale.
Where it bites
Four regimes, four different questions
The same pack can be compliant in one market and unsellable in another.
| Regime | Instrument | What it asks | Status |
|---|---|---|---|
| European Union | Regulation (EU) 2025/40 | Recyclability, recycled content, substance limits, design efficiency, harmonised labelling | Applies from 12 August 2026, staggered to 2040 |
| United Kingdom | Packaging EPR and modulated fees | Registration, tonnage reporting and fees graded by recyclability assessment | Live, with fee modulation phasing in |
| United States | Seven state EPR statutes | PRO registration, supply reporting, per-pound fees eco-modulated by material | Oregon and Colorado live; others phasing to 2032 |
| Asia-Pacific | National waste and recycling rules | Recycling targets, single-use restrictions, local labelling requirements | Varies widely by country |
Note on the United States. Seven states have enacted packaging EPR: Maine, Oregon, California, Colorado, Minnesota, Maryland and Washington. Circular Action Alliance is the designated producer responsibility organisation in most. Both live schemes face legal challenge. A federal court granted a preliminary injunction against Oregon fees for certain producers in early 2026, and litigation over California SB 54 remains unresolved. We track both rather than assume a schedule holds.
Who uses it
Four teams, one set of numbers
Exposure resolves only when the same figure appears in four plans.
Move past the pledge
Obligations quantified per SKU per market, the form the business responds to.
Defend the claim
Substantiation files behind every claim, prepared before a challenge not after.
Design to the fee
The per-tonne consequence of a structure decision, while it is being made.
Budget the liability
A forecast of recurring producer responsibility cost, built from your tonnage.
Questions
Frequently asked questions
When does the EU PPWR apply?+
Regulation (EU) 2025/40 entered into force on 11 February 2025 and applies from 12 August 2026, when Directive 94/62/EC is repealed. Requirements are staggered: substance restrictions and design efficiency rules apply from August 2026, while recyclability, recycled content and labelling phase in through 2030 and beyond.
Which US states have packaging EPR laws?+
Seven states have enacted packaging EPR laws: Maine, Oregon, California, Colorado, Minnesota, Maryland and Washington. Only Oregon, since July 2025, and Colorado, since January 2026, have live fee obligations, and Oregon is partly enjoined. California fees are expected in 2027.
Does compostable packaging avoid EPR fees?+
No. Compostable and biodegradable packaging is covered by EPR and must be reported like any other material. Treatment varies by state. California reduces fees for certified compostable packaging under eco-modulation, while Oregon and Colorado treat compostables closer to mixed plastic, because collection infrastructure is limited.
What makes a recyclability claim legally defensible?+
A defensible claim rests on evidence that the pack is collected, sorted and reprocessed at scale in the market where the claim appears, not merely that the material is technically recyclable. Regulators expect claims to be specific, qualified where necessary, and documented.
We sell into the EU from outside it. Does PPWR apply to us?+
Yes. The regulation applies to packaging placed on the EU market regardless of where the producer is established. Importers and online marketplaces carry defined obligations, and non-compliant goods can be refused at the border.
Find out what your portfolio owes
Send your formats and the markets you sell into. We come back with an exposure map, a fee forecast and the redesigns that move the number most.
Strategic Packaging Insights is a trading name of SRI Consulting Group Ltd, registered in England and Wales, company number 16581261. sales@strategicpackaginginsights.com
Last reviewed: 31 July 2026. This page describes regulatory frameworks in general terms and is not legal advice.