EPR as a Driver to Meet Sustainable Packaging Goals

Extended Producer Responsibility is a strategy or policy approach through which producers are given full responsibility for the lifecycle of the products and/or packaging they produce. It can be operational or financial, simple or complex. The program can be mandatory or voluntary because implementation and enforcement varies by country and state. The purpose is to decrease the total environmental impact of a product, and for manufacturers of products to be responsible for the entire life-cycle, especially for take-backs, recycling, and final disposal. EPR serves as a financial incentive to manufacturers to design sustainable products. Under EPR in some countries, producers may be individually responsible, or responsibility is outsourced to other companies via Producer Responsibility Organizations, or PROs.

According to the Sustainable Packaging Coalition, “The PRO then develops a producer responsibility plan and manages the producer responsibility program. In some states, these components are referred to as a stewardship organization and stewardship plan. PROs are typically required to be nonprofit organizations and a common approach is to allow for multiple PROs to operate within a single region’s EPR program.”

EPR as a Driver to Meet Sustainable Packaging Goals

EPR fees help cover the costs of infrastructure improvements, litter prevention, education, and administration. These regulations help move us closer to sustainable packaging goals with improved labeling, eco-modulation, statewide consistency, and increased education and access. 

Improved Labeling

EPR legislation can be designed to stop misleading labeling and make it easier for customers to understand how to dispose of different packaging and products. One example of a misleading label is that #5 and #6 plastics usually have the recyclable sign on them. Very few households have easy access to drop off locations for these notoriously difficult to recycle materials, and so they are often put in household recycling anyways causing contamination. Additionally, PLA packaging, an industrially compostable plastic, often carries the chasing arrows symbol with a #7, which many individuals would assume to mean “recyclable”, even though in most areas it is not.

European programs are focusing on clarifying and improving the labeling of products and packaging to help consumers better understand what is and what isn’t recyclable. There is new EPR legislation being created in the United States as well focused on improved labeling. 


Eco-modulation is a specific subset of extended producer responsibility (EPR) legislation that uses fees to incentivize more environmentally conscious packaging design and chill less sustainable alternatives. The overarching objective of eco-modulation is financing the waste recovery systems while also improving design optimization and education about the waste recovery processes. Packaging materials in the market are required to be reported on with varied fee levels based on criteria like:

  • Differentiating material characteristics (such as density and color) 
  • Current waste management infrastructure processing costs
  • The expected revenue for the material post recycling
  • Other material and format factors

According to EcoEnclose, “EPR policy could require producers to pay more if they produce a high volume of black plastics, which are extremely difficult to recycle. Similarly, producers who use high rates of post-consumer waste may pay significantly less (or nothing at all), because the system wants to encourage the development of end markets for recycled content. Strategically designed eco-modulation can help shift the design of inputs into packaging to be more circular over time. If eco-modulation helps narrow the price differential between options that are far better for the planet, we know this will help brands collectively make more responsible choices.”

Statewide Consistency

An unfortunate truth about recycling is that two households can live a few miles apart and still have very different rules about what they can and can’t recycle, all based on the materials recovery facility receiving their waste. This creates distrust and confusion, and discourages recycling overall. It can also increase the likelihood that a consumer will toss everything into the recycling even though it is not recyclable. Most EPR legislation works to create a consistent, statewide set of goods that can be recycled. In practice, the stewardship organizations would work with and financially support the material recovery facilities to ensure they can recycle the materials they are receiving.

Increased Education and Access

Finally, most proposed EPR legislation sets clear goals to improve access to curbside recycling and education around how to recycle. This would undoubtedly raise recycling rates and work towards a more circular packaging economy. 

Under the legislation in Maine, producer collection programs need to  include effective education and outreach strategies for reaching consumers in all corners of the State. Under the bills proposed in Massachusetts, the responsibility for education would be shared among the PROs, producers, state, and municipalities. In the New York proposals, the PRO would have responsibility for carrying out education programs to support the implementation of the law. You can learn more about effective communication on packaging waste at How2Recycle.

Easy EPR Reporting with Trayak

In the beginning, EPR reporting can look complicated with extensive data collection and complex fee structures. Luckily, Trayak is here to help! We now provide EPR fees and consulting services that make EPR fees easy. Empower your sustainability reporting with Trayak’s knowledge base of EPR fees across the globe. Most LCA companies don’t incorporate EPR and all too often it is totally siloed from LCA. Instead, Trayak leverages the power of EcoImpact-COMPASS by building on the extensive and accurate database of packaging and product data that you are already building. 

Trayak has been helping leading brands of all sizes make data-driven sustainability decisions for over 10 years. If you would like to learn more about our tools and services please contact us.


(SPC), Sustainable Packaging Coalition. “Extended Producer Responsibility – SPC’s Guide.” Extended Producer Responsibility – SPC’s Guide, https://epr.sustainablepackaging.org/. 

“Extended Producer Responsibility, the Planet, and Your Business.” EcoEnclose, 1 Nov. 2021, https://www.ecoenclose.com/blog/extended-producer-responsibility-the-planet-and-your-business/. 

Hasse, Gaia. “Eco Modulation of EPR Fees.” Extended Producer Responsibility in the Danish Textile Sector: Assessing the Optimal Development and Implementation, Nov. 2021, file:///C:/Users/Anna%20Oestreich/Downloads/ExtendedProducerResponsibilityintheDanishTextilesector%20(1).pdf. Accessed 20 June 2022. 

June 17, 2022. / Staff Feature, et al. “Eco-Modulation: What Does It Mean for Packaging Design and Material Selection?” SPC, 21 Apr. 2022, https://sustainablepackaging.org/eco-modulation-what-does-it-mean-for-packaging-design-and-material-selection/. 

“What Is Extended Producer Responsibility (EPR)?” WWF, World Wildlife Fund, 8 June 2021, https://www.worldwildlife.org/blogs/sustainability-works/posts/what-is-extended-producer-responsibility-epr. 

“White Paper Extended Producer Responsibility (EPR) for Packaging & Paper Products .” Apr. 2020.

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