The idea behind extended producer responsibility for packaging is simple: companies that design and sell packaging should pay for managing it at the end of its life, not local governments or taxpayers. Seven states—California, Colorado, Maine, Maryland, Minnesota, Oregon, and Washington—have passed EPR packaging laws, and more states are considering similar rules designed to unlock the circular economy.

In each state, producers, including brand owners, importers, and retailers, must register with a Producer Responsibility Organization (PRO). A PRO is usually a nonprofit that collects fees, funds recycling and collection programs, and handles reporting. The fees are based on the type, material, and weight of packaging sold in each state. For more details on how these programs work, Maine and Oregon’s early experiences offer useful insights. EPR fees vary depending on the packaging and its content.

Most large companies lack a single, organized record of their packaging. Information is spread across different teams, like product development, supply chain, legal, and sustainability, in various formats and definitions. Often, this data is pulled together manually just before regulatory deadlines.

The GS1 US Guidance for Extended Producer Responsibility (EPR) Packaging Requirements is the first industry-wide attempt to standardize how companies organize this data. It uses identifiers and formats already common in global commerce. GS1 US manages barcode standards, including the Universal Product Code (UPC), which is used in almost every retail supply chain worldwide.

The guide explains how companies can use two GS1 identifiers they probably already have. Global Trade Item Numbers (GTINs), found in barcodes, uniquely identify products and their packaging at different levels, from single items to cases and pallets. Global Location Numbers (GLNs) identify the locations products move through. Together, these create a traceable path in the supply chain, linking products to their specific packaging.

For EPR reporting, this means a company can know not just that it sold cereal boxes in Oregon, but also what those boxes are made of, how much they weigh, and how they are classified under state recyclability rules. All this information comes from existing supply chain data, so it does not have to be created from scratch.

Why This Matters Beyond the Corporate Spreadsheet

In 2024, California sent almost 8.5 million tons of single-use packaging and food containers to landfills, according to CalRecycle, the state’s recycling agency. Across the country, containers and packaging make up about 28 percent of municipal waste, but the recycling rate is well below what the system can handle. Without a way to track materials, it is hard to plan and improve recycling infrastructure to cut down on landfill waste.

EPR programs aim to fix this problem by creating a dedicated funding source for recycling infrastructure, paid for by the brands whose packaging ends up as waste. The EPA estimates that it would take $36.5 to $43.4 billion to expand collection and processing enough to raise the national recycling rate from about 32 percent to as high as 61 percent.

However, EPR fee revenue depends on the quality of the data behind it. If producers under-report their packaging, either on purpose or because their data is disorganized, PROs collect less money than needed, infrastructure is underfunded, and recycling rates do not improve. Accurate, standardized data is essential for the whole system to work.

The GS1 guidance seeks to close the gap between EPR policy and EPR implementation as new laws are passed and fee structures established. Oregon’s program has been collecting producer fees since July 2025. Colorado required producers to register with its PRO by the same date. Maine’s program comes online in 2026, with full implementation in 2027. California requires producer registration by January 2027, with escalating recyclability performance standards through 2032.

The guidance is aimed at industries with especially complex packaging, such as healthcare brands with medical product packaging, foodservice companies using single-use items and paper products, and apparel or general merchandise companies with packaging made from different materials. It is meant for sustainability, legal, supply chain, and data teams who need to work together on these issues.

“EPR requirements are evolving quickly and vary by state, creating new complexity for producers,” said Michelle Covey, vice president of customer success at GS1 US. “This guideline helps organizations take a practical, standards-based approach to managing packaging data so they can meet regulatory requirements more efficiently while also supporting broader sustainability and circular economy goals.”

The Eco-Modulation Incentive

EPR programs are designed to change what packaging looks like over time, not just how it is disposed of. Eco-modulation, built into most state programs, including those in California, Colorado, Oregon, and Washington, creates a direct financial incentive to design packaging that is easier to recycle.

Brands that use packaging that is easy to recycle, includes recycled content, or avoids materials that contaminate recycling streams pay lower fees. Brands using hard-to-recycle materials or packaging that disrupts sorting pay higher fees. If fees are high enough and data systems are accurate, companies should start investing more in truly recyclable packaging. Most states use a system called eco-modulation: packaging that is truly recyclable, easy to collect, contains recycled content, or is designed for recovery pays lower fees. Packaging that disrupts recycling or contains harmful substances costs more. The goal is to encourage better packaging design by rewarding good practices and penalizing poor ones.

Eco-modulation sounds good in theory, but in practice, it depends on producers providing detailed and accurate data about their packaging, such as material types, weights, recyclability, and supply chain information. This is where the system has faced challenges.

Whether this shift happens depends on producers being able to accurately report their packaging details. GS1’s standardized identifiers provide the audit trail needed to make eco-modulation effective instead of just an estimate.

What You Can Do

EPR laws are made by policymakers, but they also affect what people buy and how they advocate for change. Here is how individuals can get involved:

• Find out if your state has EPR packaging laws. California, Colorado, Maine, Maryland, Minnesota, Oregon, and Washington already have active programs. If your state does not, lawmakers may be considering new bills. You can contact your representatives to show your support.
• Look for packaging with clear signs of recyclability. Certifications such as How2Recycle labels are more trustworthy than general claims. You can use Earth911’s recycling search to find local programs that accept certain types of packaging.
• Choose brands that are open about what materials they use in their packaging. EPR laws are starting to push companies to be more transparent. Brands that join PRO programs and build standardized data systems are showing real commitment to compliance, not just talking about sustainability.
• Support deposit-return and reuse programs if they are available. EPR and bottle bill programs work well together. Deposit-return systems help fund collection for beverage containers, while EPR covers all types of packaging. Both approaches help reduce landfill waste.
• Try to use less packaging when you can. While EPR programs encourage better packaging design, the best way to cut packaging waste is to use less. Buying in bulk, picking concentrated products, and using refillable containers all help remove packaging from the system.

Related Reading

• Extended Producer Responsibility In 2025: Progress, With More To Come
• Learning From Maine and Oregon’s EPR Programs
• Where Is The Circular Packaging Economy In 2026?

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