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This message was posted by a user wishing to remain anonymous

Good morning, community!

As most others in our industry are, our company are attempting to navigate how the EPR packaging regulations impact our business. Ideally, we would like to think that our gross sales are low enough to gain an exemption, but that is likely a naive perspective.

Are there any other professionals in a similar situation?  Smaller brand-owners (i.e., much much closer to a startup than a Unilever sized producer) that may or may not need to register with a PRO such as the Circular Action Alliance?

Also, are fees being currently assessed for any of the eight states, or are the programs still in the data collection phase?

Hello -

The different US states have different EPR rules regarding exemptions for small businesses. Fees are only being assessed in OR at the moment. Other states are at various stages of needs assessments or initial fee development, e.g., CA.

Have you tried using the EPR.ai tool to get answers to these questions? I think you will find it very helpful.

-Conor 

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Conor Carlin
President
IOPP
Plymouth MA
(617) 771-3321
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Every state has a different threshold for small producer exemption. For CA, you still need register with cal-recycle. Fee have been assessed in several states. The best think you can do at this point is register and catch up. If you have more questions, you can email me. We help producers navigate EPR and help with engineers and data tools, if needed.

Jessie@stratpackpartners.com

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Jessica Schwartz
Founder & CEO
Strategic Packaging Partners
West Saint Paul MN
(651) 214-6577
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Hello, 

I would agree - each state has minimum thresholds so it's important to understand what those are, and how your business (sales, packaging volume, etc) fits into the mix.

For instance - Oregon has minimum threshold of Annual Gross Revenue of less than $5M - and Less than 1 metric ton of the covered packaging materials sold into the state.

Reach out if you have broader questions in this space

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Rob Kaszubowski CPP
Director, Packaging Optimization
NTT Data - Packaging Optimization (formerly Chainalytics)
Minneapolis MN
(763) 772-2455
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