Cosmetic packaging
Extended Producer Responsibility
Seven US states have packaging Extended Producer Responsibility (EPR) laws affecting cosmetics brands. Each requires producer registration, fee payment, and annual supply reporting. Pick a state for the full requirements and timeline.
Last updated:
7
States with EPR
CAA
PRO for 4 states
$5M
Typical de minimis
2025-29
Fee phase-in window
California
CA · CalRecycle (California Department of Resources Recycling and Recovery)
SB 54 — the most comprehensive packaging EPR law in the US.
Colorado
CO · Colorado Department of Public Health and Environment (CDPHE)
HB22-1355 — first US state to mandate statewide producer-funded recycling.
Maine
ME · Maine Department of Environmental Protection (Maine DEP)
LD 1541 — first US state to enact a packaging EPR law.
Oregon
OR · Oregon Department of Environmental Quality (Oregon DEQ)
SB 582 — first US EPR program to go live operationally.
Minnesota
MN · Minnesota Pollution Control Agency (MPCA)
Packaging Waste & Cost Reduction Act (2024) — Midwest's first packaging EPR.
Washington
WA · Washington Department of Ecology
Recycling Reform Act — packaging EPR advancing through Washington legislature.
Maryland
MD · Maryland Department of the Environment (MDE)
Statewide Recycling Needs Assessment — laying the groundwork for packaging EPR.
What is packaging EPR?
Extended Producer Responsibility (EPR) shifts the cost of post-consumer packaging waste from municipalities and taxpayers to the brands that put packaging on the market. Under a packaging EPR law, every brand that sells products in covered packaging is a "producer" — and producers must register with a Producer Responsibility Organization (PRO), report annual packaging volumes by material, and pay fees that fund recycling and waste management.
For cosmetics brands, EPR applies to primary packaging (bottles, jars, tubes, compacts), secondary packaging (cartons, sleeves, folding boxes), and shipping materials (mailers, void fill, tape). Fees are typically eco-modulated: more recyclable materials cost less per ton; harder-to-recycle materials cost more. This is a direct financial incentive to redesign packaging for recyclability.
The seven US states with packaging EPR laws use slightly different definitions, de minimis thresholds, and timelines, but all share core mechanics: registration, annual supply reporting, and fee payment. Four states (California, Colorado, Oregon, Minnesota) have designated the same PRO — Circular Action Alliance (CAA) — which lets a multi-state producer consolidate reporting through one organization.
EPR is the next compliance frontier
Cosmetica tracks producer obligations, supply data, and fees across all 7 US EPR states alongside your FDA, EU, and other market compliance work — one platform, one workflow.