As a member of IBA (Independent Beauty Association), I had the pleasure of sitting in on their discussion, “Extended Producer Responsibility (EPR) Packaging Regulations Roundtable Discussion: Guidance for Brands and Businesses”, during the recent LUXE PACK and MakeUp in Los Angeles.
While we are all aware that sustainable packaging initiatives and regulations are constantly evolving, this presentation highlighted the policy of “Extended Producer Responsibility (EPR)” and the onus on producers of some, if not all, of the financial responsibility for end-of-life
collection, sortation, and processing of packaging supplied into the United States.
You may ask why this responsibility has fallen onto producers. The thought behind it is that by encouraging producers to choose more sustainable packaging initially, which encourages recyclability and minimizes waste, less will end up in landfills. Incentives, targets, and financial/operational obligations are all a part of these regulations.
While “producer” is defined differently by state (please ensure you are familiar with how your state defines this), it could include brands, manufacturers, importers, 3PL fulfillment partners, distributors, or retailers. As of 2026, seven states have enacted packaging EPR laws: Maine and Oregon (2021), California and Colorado (2022), Minnesota (2024), and Maryland and Washington (2025). Several more, including New York, New Jersey and Massachusetts, have bills under consideration.
For the sake of brevity, I won’t include all the material types that fall under this legislation; please ensure you make yourselves aware of what they are. Some classes include paper/fiber, plastic, and wood/organic materials, with examples listed within. Suffice it to say, that packaging is covered by all the regulations, including consumer and some B2B. While these changes won’t happen overnight, producers should start to plan now to ensure compliance.
Choosing packaging options that are compliant with the new legislation now, including those with the lowest fee obligations, will result in less hassle and stress in the future. In addition to this, brands can use their sustainability efforts as a marketing differentiator and educate existing and potential consumers of their commitment to eco-friendly packaging. This includes choosing products whose packaging is recyclable or compostable.
Knockout Packaging Solutions works with brands like RMS Beauty, EXPONENT Beauty, Herbivore, and many more to ensure their brand promise and commitment to environmental sustainability is incorporated into their secondary packaging needs while also considering their brand aesthetics and product safety requirements.
Please contact us to learn more about how Knockout can advise you and source the most compliant packaging options to meet the new EPR regulations.
Frequently asked questions
What is Extended Producer Responsibility (EPR) for packaging?
EPR is a policy that places some, if not all, of the financial responsibility for end-of-life collection, sortation and processing of packaging on the producers that supply it into the United States. The aim is to encourage producers to choose more sustainable packaging from the start, so less ends up in landfill.
Who counts as a producer under EPR packaging laws?
It depends on the state, because each state defines producer differently. A producer could include brands, manufacturers, importers, 3PL fulfilment partners, distributors or retailers, so check how your own state defines the term before assuming who carries the financial and operational obligations.
Which US states have EPR packaging laws?
As of 2026, seven states have enacted packaging EPR laws: Maine, Oregon, California, Colorado, Minnesota, Maryland and Washington. Several others, including New York, New Jersey and Massachusetts, are considering bills. The rules cover consumer packaging and some B2B packaging across material classes such as paper and fibre, plastic, and wood and organic materials.
How should beauty brands prepare for EPR regulations?
Start planning now. Choosing packaging that already complies with the new legislation, including options with the lowest fee obligations, reduces hassle later. Recyclable or compostable packaging also gives brands a sustainability story they can use as a marketing differentiator with existing and potential customers.
Sources
- Packaging EPR State Implementation, Retail Industry Leaders Association (RILA)
