EPR Deep Dive: Minnesota

Background  

Minnesota has joined five other US states in implementing an Extended Producer Responsibility (EPR) law. The Packaging Waste and Cost Reduction Act was enacted in 2024 with strong bipartisan support, in an effort to address consumer and local government demand for sustainable solutions to mounting waste management needs. The law incentivizes companies to minimize packaging waste by using fewer materials and more recyclable content. 

What Companies Are Affected? 

Minnesota’s EPR law covers producers—any company that manufactures packaging or places products with packaging and paper onto the Minnesota market. Covered entities include brand owners, importers, and distributors in addition to manufacturers. The EPR law affects companies in nearly every sector, including: 

• Food and beverage 

• Consumer packaged goods (CPG) 

• Personal care and household products 

• E-commerce and retail 

• Publishing and print 

The materials covered include: 

• Packaging: Materials to transport, market, protect, or handle a product 

• Food packaging: Materials to market, protect, handle, deliver, serve, contain, or store food and beverages  

• Paper products: Products made from wood or cellulosic fibers 

There are certain exemptions within these categories, mostly for medical products. See Minnesota’s list of EPR-exempt materials for further information on what packaging and paper products are not covered by the law. 

Download our EPR Bulletin for essential information

Key Deadlines 

The Minnesota Pollution Control Agency (MPCA) is responsible for implementing the program, and it has established a timeline to phase in requirements: 

• July 1, 2025: Producer Registration Deadline 
  Producers must register with an approved Producer Responsibility Organization (PRO) that will manage compliance obligations on behalf of its members. 

• December 31, 2026: Initial Needs Assessment 
  CAA will conduct a needs assessment to define the program’s scope and create a basis for the PRO’s plan. 

• October 1, 2028: Stewardship Plan Due 
  CAA will submit its Stewardship Plan and including the fee schedule and prepare to collect fees from producers.  

• January 1, 2029: Materials Restrictions 
  Producers will be prohibited from introducing covered materials without entering into agreement with the PRO under the approved stewardship plan. 

• February 1, 2029: Fees Begin 
  Producers must cover at least 50% of program costs. 

• February 1, 2030: Fees Increase 

Producers must cover at least 75% of program costs. 

• February 1, 2031: Full Fee Increase 
  Producers must cover at least 90% of program costs. 

• January 1, 2032: Full Program Implementation 
  Covered materials must meet stringent program requirements on collection and disposal. 

The MPCA confirmed Circular Action Alliance as the state’s PRO on February 18, 2025, and registered producers will receive ongoing updates on critical deadlines and fee information as the program progresses.  

Minnesota EPR Program Requirements 

The end goal of the program is for all packaging, food packaging, and paper products to meet at least one of the following requirements by January 1, 2032. Packaging must be: 

• Refillable and supported by a refill system. 

• Reusable and managed through a reuse system. 

• Recyclable and collected through a curbside or other approved system. 

• Compostable and collected through a curbside or other approved system. 

To meet these goals, the PRO will collect annual fees from producers that go toward the MPCA has not yet listed fee schedules for the Minnesota EPR program. The fees will be determined in 2027, based on the program needs assessment to be carried out in 2026. 

Minnesota’s EPR fees will be “eco-modulated” to incentivize more sustainable material use. Fees will be lower for producers that: 

• Reduce or eliminate intentionally-added toxic substances. 

• Reduce the amount of paper used in manufacturing individual products and packaging. 

• Increase the amount of materials managed in a reuse system. 

• Increase the proportion of post-consumer material in production. 

• Increase recyclability or compostability.  

• Increase the proportion of inputs from renewable and sustainable sources.  

Noncompliance Penalties 

Noncompliance with Minnesota’s EPR law comes with significant civil penalties: 

• First violation: Up to $25,000 per day of violation. 

• Second violation within 5 years: Up to $50,000 per day of violation. 

• Third or subsequent violation within 5 years: Up to $100,000 per day of violation. 

Companies will also have to contend with loss of reputation among consumers and potentially business partners. 

EPR Best Practices 

There’s a lot to do to get ready for Minnesota’s EPR program implementation. In addition to registering with CAA by July 1, 2025, producers need to take the following steps. 

1. Conduct a Packaging Audit 
   Review packaging materials, types, and amounts and benchmark them against the MPCA’s recyclability requirements. 

2. Maintain Detailed Records 
   Create a rigorous record-keeping system based on your full packaging audit so you’re prepared to submit annual reports to the PRO. 

3. Collaborate with Suppliers 
   Look for opportunities to reduce packaging’s environmental impact by collaborating with suppliers to use more sustainable packaging. Consider revising supplier contracts to address EPR compliance requirements. 

4. Stay Engaged 
   Be proactive in compliance by subscribing to MPCA updates and staying current with CAA communications.  

Minnesota EPR Support from Snaplinc 

The amount of data your company needs to collect and report under Minnesota’s EPR law is significant, and the complexities are a challenge for any compliance professional. Snaplinc Consulting’s EPR experts are here to help you navigate the ins and outs of the Packaging Waste and Cost Reduction act whether you’re partway through the process or just getting started.  

Schedule a meeting with us today to learn how we can guide you toward an effective EPR compliance plan.