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Packaging rule · United States · EPR

Minnesota Packaging Waste and Cost Reduction Act

Extended producer responsibility (EPR) rule covering all packaging in Minnesota, United States, set by Minnesota Legislature / MPCA. Applies since 1 July 2025.

By the SPI teamRule ID PR-US-006Source consulted 14 October 2026Verified 14 October 2026
Sourced facts

The rule

Recorded from the official source named below. Rates and dates are as the source states them on the date it was consulted.

Jurisdiction
United States · Minnesota
Authority
Minnesota Legislature / MPCA
Rule type
EPR
Materials
All packaging
Status
In force Enacted
Adopted or published
1 July 2025
Applies from
1 July 2025
From the source

“Producers must be registered members of the PRO.”

Official source MPCA fact sheet: Packaging waste and cost reduction act (impacted parties)Official (government or regulator) · consulted 14 October 2026

Deadlines

Key dates

  1. Adopted or published 1 year and 3 months ago

  2. Applies from 1 year and 3 months ago

  3. Source consulted by the SPI team today

  4. Re-checked by a second SPI team member today

SPI analysis

What it means

SPI analysis Our reading of the official source above. Not legal advice; always rely on the official text.

SPI summary

Minnesota's 2024 law requires packaging and paper producers to be registered members of a PRO (Circular Action Alliance) from 1 July 2025. The first stewardship plan is due 1 October 2028 and producer-funded reimbursement of service costs starts in 2029.

In practice

Minnesota's Act requires producers of packaging, food packaging and paper products sold into Minnesota to be registered PRO members from 1 July 2025; MPCA accepted Circular Action Alliance's (CAA) registration as PRO. Costs arrive later: the first stewardship plan is due 1 October 2028, and producer funding of service provider costs phases in from 50% in February 2029 to at least 90% in February 2031. From 2032 covered materials are to be refillable, reusable, recyclable or compostable.

Where the record is unclear

  • Small producer thresholds are not stated in the MPCA fact sheet or web page.
  • The record states CAA was registered in February 2025; MPCA confirms acceptance of CAA's registration but gives no date.
  • The 1 July 2028 date for collection lists and statewide requirements is marked by MPCA as not set in statute.
  • Statewide numeric targets are still to be set by MPCA.

Where it sits in the tracker

  • One of 13 packaging rules we track in the United States, of which 7 are EPR rules.
  • In all, 25 EPR rules are tracked across 15 jurisdictions. Compare them below

Company profiles that map to this rule

Companies whose SPI profile lists this rule in its regulatory exposure, based on where they report selling. Not company-reported.

SPI analysis

Overview

The Packaging Waste and Cost Reduction Act is codified at Minnesota Statutes sections 115A.144 to 115A.1463 and was enacted by Laws 2024, chapter 116, article 514. It requires producers of packaging, food packaging and paper products to fund, through a single producer responsibility organisation, most of the cost of reuse, recycling and composting services that Minnesota's local governments and haulers now provide1. MPCA oversees the programme, approves stewardship plans and annual reports, and enforces the Act1.

The Act is built in stages rather than switched on at once. The PRO had to register by 1 January 2025, producers had to be members from 1 July 2025, and from 1 January 2029 no producer may introduce covered materials without a written agreement under an approved stewardship plan39. Reimbursement of service providers' net costs then climbs from at least 50% on 1 February 2029 to 75% in 2030 and 90% from 2031 (section 115A.1455, subdivision 4)6.

The longer aim is design change. From 1 January 2032, covered materials must be reusable, refillable or on MPCA's recyclable or compostable lists, and covered services must be available, although the PRO may petition for extensions up to 1 January 20403. On the live tracker the rule still reads adopted, a label being updated in the 13 October check, since membership has been mandatory from 1 July 2025.

Duties

Who must do what

Producer (from manufacturer down to first distributor into Minnesota)

  • Be a member of a PRO registered in Minnesota after 1 July 2025 (section 115A.1448, subdivision 1(a))3.
  • From 1 January 2029, introduce covered materials only under a written agreement with a PRO operating an approved stewardship plan (subdivision 1(b))3.
  • From 1 January 2032, introduce covered materials only where covered services are provided and the materials are reusable, refillable or listed under section 115A.1453 (subdivision 1(c))3.
  • Pay producer fees under section 115A.1454 and implement the stewardship plan (subdivision 2)3.

Importer of record

  • Becomes the producer of a retail item when nobody higher in the subdivision 26(a)(1) order is present in the United States (item (iv))2.

Circular Action Alliance (registered PRO)

  • Register annually from 1 July 2026 and each 1 January after, listing member producers, their brands and copies of their written agreements (section 115A.1443)9.
  • Submit a stewardship plan by 1 October 2028 and every five years, with reuse, return, recycling, composting, waste reduction and recycled content targets by material type (section 115A.1451)5.
  • Set producer fees per ton or per item, net of commodity value, with eco-modulation for toxics, source reduction, reuse, post-consumer content, recyclability and renewable inputs; fees may not fund lobbying (section 115A.1454)7.

Minnesota Pollution Control Agency (commissioner)

  • Commission an independent needs assessment, preliminary by 31 December 2025 and first full by 31 December 2026, then every five years (section 115A.1450)8.
  • Review the stewardship plan within 120 days after at least 45 days of public comment, and set the registration fee from 1 January 2029 with notice by 1 October 202859.
Scope

Are you in scope?

Work through each question. The answers are the SPI team's reading of the sources cited.

  1. In your most recent fiscal year, did you have global gross revenues under $2,000,000 or introduce under one ton of covered material into Minnesota?

    If yes
    You are a de minimis producer and excluded from the producer definition (section 115A.1441, subdivisions 13 and 26(b))2.
    If no
    Apply the producer hierarchy in subdivision 26(a)2.

  2. Are you a government unit, or a nonprofit exempt under section 501(c)(3) or (c)(4)?

    If yes
    Subdivision 26(b) excludes you from the producer definition2.
    If no
    The de minimis and hierarchy tests apply.

  3. Is the packaging business-to-business packaging used to produce another product and not passed to a consumer?

    If yes
    MPCA lists it as exempt1.
    If no
    It is covered material if introduced in or into Minnesota, including through online sales12.

  4. Does it hold an FDA or EPA regulated product, infant formula, medical food, refillable LPG or paint in an approved stewardship programme?

    If yes
    MPCA lists these product packaging categories as exempt1.
    If no
    The Act applies.

  5. Is it a bound book, or a newspaper or magazine with circulation under 95,000 that meets MPCA's content criteria?

    If yes
    The paper product is exempt1.
    If no
    Paper products are covered material2.
Checklist

Compliance checklist

  1. Confirm membership and producer identity

    By Now (required since 1 July 2025)

    SPI analysis of the official text. Not legal advice; confirm with the text or counsel. Work through the subdivision 26(a) hierarchy for each product, including e-commerce packaging rules and any contractual assignment, and confirm PRO membership23.

    Evidence to keep Producer map and membership confirmation.

  2. Comment on the 2026 Needs Assessment

    By 13 November 2026

    The assessment becomes the baseline for judging whether statewide requirements and targets are met, so its tonnage and cost figures shape later fees (section 115A.1450, subdivision 5)18.

    Evidence to keep Submitted comments and the data relied on.

  3. Review the draft stewardship plan

    By Before 1 October 2028

    The advisory board sees the draft at least 60 days before it goes to MPCA, followed by at least 45 days of public comment5.

    Evidence to keep Notes on targets and fee design in the draft.

  4. Sign the written PRO agreement

    By 1 January 2029

    Without it a producer may not introduce covered materials in Minnesota (section 115A.1448, subdivision 1(b))3.

    Evidence to keep Executed agreement.

  5. Budget for reimbursement-driven fees

    By 1 February 2029

    Fees must cover reimbursement of at least 50% of net costs from 2029, 75% from 2030 and 90% from 2031, plus a prudent reserve67.

    Evidence to keep Three-year fee forecast by material.

  6. Redesign formats for 2032

    By 1 January 2032

    Formats that are not reusable, refillable or on the section 115A.1453 lists cannot be introduced after this date unless an extension is granted3.

    Evidence to keep SKU list against the MPCA lists.

Enforcement

Enforcement and penalties

Who enforces
Minnesota Pollution Control Agency commissioner, under sections 115A.1462, 115.071 and 116.0724
Powers
The commissioner enforces the Act and can revoke the registration of a PRO or service provider found in violation4.
Enforcement so far
SPI is not aware of any penalty under section 115A.1462 as of 14 October 2026.

Penalties

BreachPenaltyLegal basis
Any person violating the Act or a related rule (general)up to $25,000 per day of violationMinn. Stat. 115A.1462(b)4
Producer or PRO, second violation within five years after stewardship plan approvalup to $50,000 per dayMinn. Stat. 115A.1462(c)4
Producer or PRO, third or later violation within five years after stewardship plan approvalup to $100,000 per dayMinn. Stat. 115A.1462(c)4

Both penalty paragraphs apply notwithstanding the general limits in section 115.071, subdivision 3, so the Act sets its own, higher ceiling4. The escalation window opens only once a stewardship plan is approved, which cannot happen before the 1 October 2028 submission45.

Connections

How it fits with other rules

Timeline

History of the rule

  1. Act signed into law; Laws 2024, chapter 116, article 514.

  2. Deadline for PRO registration and for producers to appoint a PRO9.

  3. Producers must be members of a registered PRO3.

  4. Preliminary needs assessment due8.

  5. First annual PRO registration9.

  6. Today

  7. Comment deadline on the draft 2026 Needs Assessment1.

  8. First full needs assessment due8.

  9. First stewardship plan due; MPCA notice of the 2029 registration fee59.

  10. Written PRO agreement required to introduce covered materials3.

  11. Reimbursement of at least 50% of service providers' net costs6.

  12. Reimbursement reaches at least 90%6.

  13. Covered materials must be reusable, refillable or listed as recyclable or compostable3.

Questions

Questions

Which producers count as de minimis in Minnesota?

A producer that, in its most recent fiscal year, had global gross revenues under $2,000,000 or introduced less than one ton of covered material into Minnesota. Either test is enough under section 115A.1441, subdivision 132.

When do Minnesota producers start paying for recycling services?

Producer fees fund reimbursement of service providers from 1 February 2029, at no less than 50% of net cost. The floor rises to 75% in 2030 and 90% from 20316.

What changes in Minnesota on 1 January 2032?

Producers may introduce covered materials only where covered services are provided and the materials are reusable, refillable or on MPCA's recyclable or compostable lists. The PRO can petition for two-year extensions, then yearly ones, up to 1 January 20403.

How large are Minnesota's penalties?

Under section 115A.1462 a violation can draw a civil penalty of as much as $25,000 for each day. For producers and PROs, a second violation within five years of plan approval can reach $50,000 per day and a third $100,000 per day4.

Is the Minnesota rule in force in the SPI tracker?

The membership duty has applied since 1 July 20253. The live record still shows adopted; the label is being updated in the 13 October check to match.

Glossary

Definitions

De minimis producer
A producer with global gross revenues under $2,000,000, or under one ton of covered material introduced into Minnesota, in its most recent fiscal year (section 115A.1441, subdivision 13)2.2
Introduce
To sell, offer for sale, distribute or use to ship a product within or into Minnesota (section 115A.1441, subdivision 20)2.2
Covered material
Packaging and paper products introduced into Minnesota, other than exempt materials (section 115A.1441, subdivision 10)2.2
Producer responsibility organization
A nonprofit corporation, tax exempt under 501(c)(3), created by a group of producers to carry out the Act (section 115A.1441, subdivision 27)2.2
Sources

Sources for this analysis

  1. MPCA: Packaging Waste and Cost Reduction Act Regulator · Consulted 14 October 2026
  2. Minnesota Statutes: section 115A.1441, Definitions Official · Consulted 14 October 2026
  3. Minnesota Statutes: section 115A.1448, Producer responsibilities Official · Consulted 14 October 2026
  4. Minnesota Statutes: section 115A.1462, Enforcement Official · Consulted 14 October 2026
  5. Minnesota Statutes: section 115A.1451, Stewardship plan Official · Consulted 14 October 2026
  6. Minnesota Statutes: section 115A.1455, Service provider; reimbursement Official · Consulted 14 October 2026
  7. Minnesota Statutes: section 115A.1454, Producer fees Official · Consulted 14 October 2026
  8. Minnesota Statutes: section 115A.1450, Needs assessments Official · Consulted 14 October 2026
  9. Minnesota Statutes: section 115A.1443, Registration of producer responsibility organizations and service providers Official · Consulted 14 October 2026
  10. Maine DEP: Stewardship Program for Packaging Regulator · Consulted 14 October 2026
  11. Colorado General Assembly: HB22-1355, signed act (C.R.S. 25-17-701 to 25-17-716) Official · Consulted 14 October 2026
  12. MPCA fact sheet: Packaging waste and cost reduction act (impacted parties) Consulted 13 October 2026

Written by the SPI team on 14 October 2026. Sources checked as of 14 October 2026. SPI analysis, not legal advice; always rely on the official text.

Audit trail

Change history

Verified: a second SPI team member re-checked every fact above against the source on 14 October 2026. Any later change to the facts sends the rule back to Sourced and is logged here.

  1. Verified by a second SPI team member

  2. Changed: status, SPI summary

  3. Verified by a second SPI team member

  4. Added to the tracker

Spotted an error? Write to sales@strategicpackaginginsights.com quoting PR-US-006 and the source. Corrections are logged in this history.

Other jurisdictions

EPR rules elsewhere

The same type of rule for the same materials in other jurisdictions, by the date it applies.

RuleWhereTypeMaterialsStatusApplies from
Containers and Packaging Recycling ActPR-JP-002JapanEPRPlastic, Paper and board, GlassIn force1 April 1997
Packaging EPR (Resolution 1407 of 2018)PR-CO-001ColombiaEPRAll packagingIn force2 August 2018
Extended Producer Responsibility Regulations and paper and packaging schemePR-ZA-001South AfricaEPRAll packagingIn force5 May 2021
EPR Guidelines for plastic packaging (PWM Rules Schedule II)PR-IN-001IndiaEPRPlasticIn force16 February 2022
Reverse logistics recycling credit certificates (Decree 11.413/2023)PR-BR-001BrazilEPRAll packagingIn force14 April 2023
Packaging collection and recovery targets under Ley REP (DS 12/2020)PR-CL-001ChileEPRAll packagingIn force16 September 2023
Germany Single-Use Plastics Fund Act (EWKFondsG)PR-DE-002GermanyEPRSingle-use plasticIn force1 January 2024
Sustainable Waste Management (EPR) Regulations, 2024PR-KE-002KenyaEPRAll packagingIn force4 November 2024
Quebec modernized selective collection (EPR) systemPR-CA-006Quebec, CanadaEPRAll packagingIn force1 January 2025
UK packaging EPR regulations (pEPR) 2024PR-GB-002United KingdomEPRAll packagingIn force1 January 2025

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