Packaging EPR Glossary
The vocabulary of packaging Extended Producer Responsibility, defined in plain language. If you are new to EPR compliance, start here — these terms appear across every state program in the directory.
- Extended Producer Responsibility (EPR)
- A policy approach that makes the producers of packaging financially and operationally responsible for the end-of-life management of the materials they put on the market. EPR shifts recycling costs from taxpayers and municipalities to the companies that design and sell packaging.
- Producer Responsibility Organization (PRO)
- A non-profit entity that administers an EPR program on behalf of producers — collecting fees, reporting data to the state, and funding collection and recycling infrastructure. In most US packaging EPR states, the Circular Action Alliance is the approved PRO.
- Circular Action Alliance (CAA)
- The producer-led non-profit selected as the Producer Responsibility Organization in most US states with packaging EPR laws, including California, Colorado, Oregon, Minnesota, Maryland, and Washington. Producers register and report through CAA.
- Producer
- The party legally responsible for a packaging EPR obligation — typically the brand owner, manufacturer, or first importer that sells a packaged product into a regulated state. The exact definition and hierarchy vary by state statute.
- Covered Packaging
- The categories of packaging and paper products subject to an EPR program — commonly single-use primary, secondary, and tertiary packaging plus printed paper, and in some states food service ware. Exemptions vary by material and use.
- Eco-modulation
- A fee structure that raises or lowers a producer's EPR fees based on the environmental attributes of their packaging — material type, weight, recyclability, and recycled content. It rewards recyclable, low-impact designs and penalizes hard-to-recycle materials.
- Post-Consumer Recycled Content (PCR)
- Material recovered from products that consumers have used and discarded, then reprocessed into new packaging. Higher PCR content typically lowers eco-modulated EPR fees and may be mandated by some state targets.
- Source Reduction
- Reducing the amount of packaging used at the design stage — through lightweighting, eliminating unnecessary components, or redesign. California's SB 54 sets statutory source reduction targets for plastic packaging.
- Food Service Ware
- Single-use items used to serve or transport prepared food and beverages — cups, clamshells, containers, utensils, and wraps. Several state EPR laws (notably California and Oregon) include food service ware as covered material.
- Stewardship Organization (SO)
- The term Maine uses for the entity that administers its packaging EPR program. Unlike the producer-run PRO model, Maine's Department of Environmental Protection contracts a single Stewardship Organization, and producer fees reimburse municipalities for recycling costs.
- De Minimis Threshold
- A minimum revenue or tonnage level below which a small producer is exempt from EPR obligations. Thresholds are set per state, so a producer can be obligated in one state and exempt in another.
- Needs Assessment
- A statutorily required study of a state's current recycling system — capacity, costs, and gaps — that informs the PRO's program plan and fee structure. Maryland's SB 901 began with a statewide recycling needs assessment.
- Recyclability
- Whether a packaging material can actually be collected, sorted, and reprocessed through the recycling systems available in a given state. EPR programs increasingly tie both fees and on-package claims to real-world recyclability rather than theoretical recyclability.
- Program Plan
- The detailed operational and financial plan a PRO submits to a state agency for approval, setting collection targets, fee schedules, and timelines. Producer obligations and deadlines typically flow from the approved program plan.
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