2025 EPR Recap + Why 2026 Is The Year Responsible End Markets Scale US Recycling
In 2025, Extended Producer Responsibility (EPR) in the United States moved decisively from theory to operational reality, laying the groundwork for scaled investment in responsible end markets. Today, Christine Yeager tackles how this shift played out across key states, with Oregon launching the nation’s first modern packaging EPR system, approving fee schedules, and advancing infrastructure projects like the Ashland Modernization Project despite legal challenges, while Colorado finalized its program plan and published fees ahead of major recycling infrastructure expansion in 2026. As California prepares to issue its first EPR invoices—creating significant financial implications for producers—and Circular Action Alliance consolidates reporting deadlines, Christine explains why 2026 will be the year outcomes materialize: service providers seek reimbursements, producers redesign packaging to reduce fees, collection systems mature, and responsible end markets begin to scale across the U.S.
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2025 EPR Recap + Why 2026 Is The Year Responsible End Markets Scale US Recycling
EPR Becomes Operational In The U.S. (2025 Recap & 2026 Outlook)
Welcome back to the show. Our episode will be our final one for the year. We will take a moment to reflect on where we have been in 2025. More importantly, we headed in 2026 as it relates to the circular economy. This year was a transformative year for Extended Producer Responsibility in the US. We are no longer seeing EPR as a theory or thing that is coming down the pipeline. We are seeing it start to operationalize. We are seeing money start to flow out into the system. New implementations are happening in the world of recycling.
The producers, who are obligated, have felt the discomfort that comes with being compliant and taking the necessary steps. In 2026, that is going to be the first big year where the rubber meets the road. We are going to start to see a lot more investment. We just saw Oregon get kicked off in 2025. In 2026, you are going to see more investment in Oregon and in Colorado. There is going to be invoicing for California.
Though producers are having to pay their invoices, they are getting hit with their full invoice for Colorado and a full-year invoice for Oregon. We are going to see responsible end markets become a phrase that everyone starts to wish they knew more about, maybe understood better, but just something that is going to be talked about a lot more.
EPR Fundamentals & Key Vocabulary
As the last episode of the season, I do not know if you’re joining now or if you’ve been following along the way, but I do want to ground everyone on a couple of vocabulary terms that I think will be important as I summarize this year and next year. Of course, there is EPR, Extended Producer Responsibility. This is the legislation that we talk a lot about here on this show because it is very active right now in playing a very active role in driving the circular economy and increasing recycling in the United States.
It is a very big topic to be talking about in this space, but it is also complicated, confusing, and ever-changing. That may be why you are here. Also, another vocabulary item I want to talk about is PRO, Producer Responsibility Organization. In the United States, for paper, packaging, EPR, or Extended Producer Responsibility laws, the Circular Action Alliance is the approved PRO, or Producer Responsibility Organization.
A producer responsibility organization is an organization that brings together the obligated producers for a particular law. In this case, paper, packaging extended producer responsibility. They are effectively required to ensure that producers are compliant, and implement the spirit of the law, so spirit, actualize the law. That means writing program plans, creating systems for producers to register, report, and then invoicing those producers, creating mechanisms for the industry to get reimbursed by the industry, which is called in this space service providers.
When you think about EPR, you have two sides of the EPR coin. You have the producers that are paying for the material that they are generating, and the waste that they are generating in the state. Then you have service providers who, in essence, should be getting reimbursed for the cost of recycling in the given state. One other vocabulary term that is important is responsible end markets. The idea behind EPR is to incentivize the creation of responsible end markets. All of this is going to be important as I talk about what is happening in 2025, even more so as we move into 2026. Let us dive in.
The idea behind EPR is to incentivize the creation of responsible end markets.
Oregon Leads: First Modern Packaging EPR In Action
What happened this year related to EPR? The headline is really that EPR got real. 2025 was the first year that EPR in the United States truly shifted from planning to execution. Not everywhere, not perfectly, and not quietly, but it is what happened. Oregon led the way. They became the first state to operate a modern packaging EPR system. Circular Action Alliance launched reimbursements for haulers, MRFs, processors, and local governments. They also published the directing the manufacturing guidance, which added a lot more clarity around who is obligated, in what scenarios.
The Ashland Modernization Project kicked off. You may not know what that is, but basically, in the nerdy world of recycling, it is an exciting development in Oregon where they created these drop-off, almost like shipping containers, that are plopped in various communities across Oregon to create an expansion of access to drop off your recycling in Oregon.
There was a lawsuit in Oregon that you may have heard about, where the American Association of Wholesalers, I believe, is the acronym, is the name of the organization. Anyway, this Wholesaler Association brought a lawsuit against the state of Oregon about their EPR, and the constitutionality of it. That is something that is not necessarily progress towards EPR, but it is something to watch. It is important to understand. I do not think that we will see a lot of decisions made anytime soon related to that, but we may see more lawsuits in other states.
Colorado & California Scale Up Implementation
Nonetheless, there is some constitutional challenge happening in the Oregon EPR. Colorado has finalized its plan. It is very close to being able to flip the switch. Earlier in December, just a few days ago, CDPHE approved the Colorado program plan that the Circular Action Alliance created. Now we know what is approved. CAA, Circular Action Alliance, has also published final fee schedules for both Oregon, Colorado for the year 2026. People should know what their invoices are going to look like in Q1 of 2026. In Colorado, the service provider reimbursement program will begin in Q1 of 2026.
We should start to see some infrastructure, access expansion beginning next year. Colorado is going to be the first state where we will truly see a lot more scale because the way that the program is structured is that it is meant to cover 100% of the cost of recycling in the state in year one. We will see a big boom because of the way that should hopefully be implemented.
In California, what happened in 2025, if you are keeping track of covered material categories, you would have seen that they published a covered material category in January, again in July, and again in September. Reporting was due in November of this year. California is quickly working its way through the rulemaking process, defining the responsible end market, defining reuse, but it is also beginning to get very real in California, as reporting was due for this first round in November.
There is an anticipation that is communicated by CAA that we will see some more reporting or reporting verification happening at the beginning of next year. They announced what they are calling early fees, which are basically your startup costs, the fees that will cover the startup costs effectively. They are much lower than what we will anticipate seeing. There is a fee schedule out there now related to the state of California. People can start to use that to understand what their California invoices might look like.
Some other states have built some momentum this year as well. The way I am thinking about the progress in EPR is you have got Oregon, Colorado, and California are the big states where a lot of things are happening. They are further along in their deadlines, things like that. The other states are also chugging along. Maine has shared its recyclability list. It is beginning to help producers prepare for registration and reporting. Maryland is continuing down the path with the needs assessment, outlining a plan-by-plan recyclability validation.
Minnesota began developing its statewide recyclability list, finalizing pro selection, and producer responsibility organization. Washington kicked off work on its 2027 collection list, long-range system design. That is what has been happening this year related to EPR. What should we expect in 2026? This is going to be, in my opinion, really the first real operational year.
It will be at least the first full year of program implementation. Oregon did invoice and begin implementation this year in 2025, but it was only a half-year of the program. Next year is going to be a full year for both Oregon and Colorado. You will see reimbursements begin in Q1 of 2026 or continue in the case of Oregon, but you should hopefully see more service providers understand their opportunity in this space and request reimbursement.
In Colorado, specifically, they have actually already started now. If you are a municipality or an MRF, you are already able to request reimbursement. Also, if you are a processor, but then it will expand out at the beginning of next year. There is a producer reporting deadline. One thing that is happening with Circular Action Alliance is that they are going to start to consolidate producer reporting deadlines where possible. Colorado's producer reporting deadline will be May 31st of 2026.
That will also be a reporting deadline for Oregon, possibly another reporting deadline for California, and potentially Maine. In Colorado, other things that are happening are that service provider contracts are ramping up. There is going to be an evolution of fee estimation in line with the program plan details. We will see how this starts to begins to reshape the industry. You may see producers start to think about how they might change their packaging design in order to reduce their fees.
Colorado is where we will learn whether large-scale EPR in the United States can actually start to deliver results. Oregon is also entering its full calendar year for operations. Oregon is the first place where we should really see some outcomes. There is going to be continuous monthly reporting from the service provider space. This will start to create transparency. Also, just in general, we will have a lot more knowledge about what is going on.
Reimbursement will stabilize for MRFs, processors. Hopefully, more and more will start to participate. In the same way in Colorado, you should start to see the fees begin to drive some changes in producer behavior as it relates to where there are opportunities to reduce my fees by changing out of certain materials. In collection will accelerate. These drop-off centers will be more settled. There should be more of them. We will start to see some numbers tick up as it relates to collection in Oregon.
We can think about Oregon as to become where we will learn what is working, and what is not, in this state. California is going to be shifting from theory to pressure. People will see their first invoice for the state of California in 2026. It will not be a full invoice. It will not be what they are expected to pay year over year for the next however many years, but it will start to give a picture of what this is going to cost in a state that usually is a very large percentage of a company's sales.
Responsible End MaResponsible End Markets As the Gatekeepers Of Circularityrkets As the Gatekeepers Of Circularity
We should hopefully not see too many material category updates as far as changes to the material categories, but we might see more clarity on what does and does not fall within the material categories in that state. We should see the program plan start to take shape next year. CAA has to deliver a program plan. Now that rulemaking should wrap up, that program plan is expected to start to take shape next year.
In summary, California is on the path to reshaping what recyclable means in the United States. Because the state of California has this very specific aspect of the legislation around plastic reduction, you will see that play out in how people evaluate, because now that you have the reporting of what all is in your portfolio that has plastic, and what that means from a fee perspective.
California is on the path to reshaping what recyclable means in the United States.
You will see companies start to rethink what needs to change about their long-term innovation strategy to not be crippled by the fees expected in California. At least smart companies will start to do this ahead of time. Some of them might have to wait another year or two because they have other things on their plate. The early adopters, you will start to see that coming through. Maine, Maryland, Minnesota, and Washington all have a series of deadlines that are mentioned.
When you look at timelines out there, if you look at the statutes, I think that for those states, it will be a lot of getting more clarity from Circular Action Alliance on truly when producer registration needs to happen, what does producer registration look like, and when will we start to see reporting? Maine mentions that there needs to be startup fees covered.
How does that come to life, because the Circular Action Alliance still needs to be selected as the PRO for that state? In general for, for Maine, Maryland, Minnesota, we will just, we will just see the evolution. We will get a lot more clarity on the next steps in those states. That is what is going to be happening in a broad sense. I mentioned earlier, 2026 is going to be where the rubber meets the road as it relates to EPR implementation. People are going to start thinking and talking a lot more about responsible end markets.
Why is that? It is because in order to bring down your fee for a particular material, you need there to be a responsible end market where that material has a value at the end of its use. For example, aluminum is a highly valuable material. It is used in planes. It is used in cars. It is used all over. It is used in cans as well. There is a lot of value to the material itself. There is even more value because you are able to extract it. You do not have a lot of loss when you recycle it. Aluminum has a high value at the end of the first use of it or the second use or whatever.
The EPR fee associated with aluminum is pretty low compared to, let's say, flexible plastic. You will start to see this investment, this eye-opening from the industry around how we start to build responsible end markets in the spaces where we do not have them, especially when it comes to the fact that in California, something needs to be deemed recyclable for it to stay on the shelf or sold into the state by 2032.
Everything that is sold into the state has to have a yes next to the material category in the definition of recyclable. The only way it will get that is if it is collected and processed. There is a responsible end market. Now, the responsible end markets start to become the gatekeepers of the circular economy, the progress that we need to see in EPR. Until now, US recycling has been held together with recyclability claims, fragmented downstream markets, but EPR is meant to shift that. Hopefully, make it more obsolete and really infuse investment to create an end market where these materials are used again and again.
So now, responsible end markets start to become the gatekeepers of the circular economy and the progress we need to see in EPR.
To no longer for it to be true that, like recycling does not work, recycling is not real, which is not true across the board, but it is true in a lot of places. The element that really needs to change is that we need to create a market for the end of life of the material. If a material is not considered recyclable, unless it is collected at scale, it is sortable by a real MRF.
It can be processed into usable feedstock. An actual end market is willing to buy it. Only then will it meet the definition of a responsible end market. Each state has some level of nuance within there, but basically, all of that needs to be true for the criteria of a responsible end market to be met. That means that this EPR investment will need to create more collection at scale.
It will need to create a way for the material to be sorted at scale. It will need to create the process. It needs to invest in the processors to process the material and then turn it into usable feedstocks. The industry will need to create a way for them to use that material so that there is actually an end market. Somebody is willing to buy it. The theory behind EPR is that the reimbursements help fund that and move it along. There is a lot of innovation out there, but it is not scalable yet. Hopefully, those innovators can come, get reimbursed, or help accelerate their scalability through EPR investment.
Who is going to benefit from EPR progress in 2026? You might see the RPET market benefit. You might see the corrugated market benefit, the recycled corrugated market benefit, or the cardboard. You might see mixed paper. Also, maybe organic processing, composting, because they fall into the scope in most states. You might see high-performing MRFs or more high-performing MRFs start to benefit from EPR in 2026. The folks who are going to struggle are with low-value flexible plastic, especially low-value flexible plastic that is then recycled, which has no buyer.
You are going to see multi-material laminates. There is a very high fee associated with multi-material laminates. Any market that is relying on an export market for recyclability is probably going to suffer. Downcycling pathways are not considered a responsible end market in some states. Now, some states will allow downcycling, but many states of Colorado, there is some nuance around what they will accept within the responsible end market.
I am excited for 2026. I know that 2025 has been hard for producers. It probably feels like you are trudging along through EPR. The groundwork is there. Hopefully, 2026 will be an easier reporting year for many producers. Hopefully will start to see some benefit in the industry from a recycling standpoint from all of these efforts. It will start to feel a little worth it, hopefully. I am optimistic for 2026 from a recycling investment standpoint.
We still have a long road ahead of us in EPR. Some of these states do not really come online until like 2028, 2027, 2030. There is still a lot of change coming as it relates to EPR. Again, this is only one aspect of the circular economy. I am closing out this year with optimism. I am starting to think about what we want to do next.
Looking Ahead: Season Two & Confronting The Messiness Of EPR
What could season two look like? I have been thinking a lot about this idea. I obviously am a recycling nerd. Not everybody is. I have a lot of belief in the fact that even though recycling has been flawed for so long, there is a possibility. At the same time, in the spirit of leaning into discomfort, I want to unpack the good, the bad, and the ugly of EPR next year. I want to confront that discomfort head-on. Talk about the confusion that we are seeing, the internal resistance people might be seeing at their companies, the policy messiness, the evolution, and how that evolution is the change that is happening in the policies being different.
All of this messiness is impacting the potential success of EPR in the long run. I also want to talk about the opportunity, the risk that comes with reshaping how products move through the economy. With each topic, I will do what I was doing at the beginning of this season, and try to have a deep dive episode where we go deep on a particular topic.
I break down what is working, what is not, and what is coming. I will try to pair it with a candid conversation from someone in the field, whether it is a brand, an end-market, a recycler, policymakers, or anybody in this space. I want to talk to the people who are really living this transition in real time.
Frankly, they are not afraid to tell the truth about it. If you know anyone who you think would be great to be on the show, or if you, as a listener, are interested in being on the show, please reach out to me. I am just Christine Yeager. Nobody famous, so do not be afraid. Honestly, this community of people in the recycling space, the circular economy space, and in the space of trying to drive change, is just a very approachable, welcoming, and purpose-driven group. I would love to hear from you.
Ultimately, I am hoping to tell stories that are behind the systems, and really unpack moments where change knocked people off balance. What decisions did they make anyway, despite being knocked off balance? Season two will launch in Q1 of next year, likely the end of January, early February, depending on how many guests I can get recorded early in the year.
It is basically going to be all about the fact that there is never a good moment to sugarcoat things. I want to move beyond sugarcoating the circular economy. Start talking about what it takes in order to drive this change in recycling, beyond reuse and composting, which is a form of recycling. Nonetheless, I want to be honest about the fact that EPR is not the silver bullet. There are a lot of people doing things beyond, outside of EPR states.
I want to continue to learn from each other about what it takes to drive change. Thank you so much for joining me in season one. Get ready for season two, where I hope we can just go even deeper. Embracing change is because is where impact starts. You cannot make an impact if you are not trying to drive change. Thank you for being here.
Important Links
Ashland recycling center first in series of new facilities part of Oregon’s Recycling Modernization
NAW Takes Legal Action Against Oregon’s Overreach on Recycling Mandate