U.S. Plastics Pact Publishes Consensus EPR Policy Paper to Guide State Packaging Circularity Efforts
The U.S. Plastics Pact (USPP) has taken a significant step toward shaping the future of packaging sustainability in the United States with the release of its first-ever policy position paper on Extended Producer Responsibility (EPR). This milestone document presents a consensus-driven framework designed to guide policymakers as they develop—or refine—state-level EPR legislation for plastic packaging. At a time when states nationwide are grappling with rising waste management costs, uneven recycling systems, and the urgent need to transition toward a more circular economy, the USPP’s new position paper offers a rare and unified perspective backed by the entire packaging value chain.
Rooted in extensive collaboration, the position paper reflects months of structured engagement between brands, retailers, packaging producers, recyclers, material recovery organizations, NGOs, government representatives, and technical experts. To ensure a balanced and representative output, the USPP conducted a comprehensive value-chain survey, organized a hybrid workshop to break down EPR fundamentals, and facilitated multiple review rounds among its network of members—known as “Activators.” Through this iterative approach, stakeholders provided detailed feedback that helped refine and strengthen the final guidance. The result is a document that not only outlines priorities but also reflects real-world experience and practical considerations from every corner of the plastics ecosystem.
Megan O’Brien, Program Manager for Reporting and Special Projects at the USPP, emphasized the unique strength of the process: “There is no shortage of EPR guidance in the marketplace — but what makes this one different is the process behind it. This paper reflects genuine consensus across stakeholders who don’t always come to the table with the same priorities. Its value is that the Pact has already navigated the hard conversations, giving policymakers a credible, balanced foundation to build from.” Her remarks capture the complexity of EPR debates in the U.S., where varying interests and state-specific challenges often lead to fragmented policies. The USPP aims to reduce that fragmentation by providing a harmonized starting point that still leaves room for regional customization.
At the heart of the position paper are six core policy levers that the USPP considers essential for designing strong, effective, and future-ready EPR programs. These levers—Funding Model, Funding System Design, Fee-Setting & Eco-modulation, Performance Targets, Responsible End Markets, and Covered Materials—serve as building blocks that states can mix and match to design an EPR system suited to their operational and economic contexts. While the structure allows flexibility, the intention is clear: EPR programs must be comprehensive, transparent, and aligned with broader circular economy goals if they are to succeed.
USPP’s earlier roadmap, Roadmap 2.0, along with globally recognized frameworks from the Ellen MacArthur Foundation, informed much of the guidance. The paper emphasizes clear definitions, pragmatic initial targets, transparent rules for responsible end markets, and mechanisms that ramp up ambition over time. These principles help ensure that recycling infrastructure, market demand for postconsumer recycled (PCR) materials, and system-wide accountability progress in tandem.
Preston Peck, Senior Sustainability Analyst for the City of Tacoma, Washington, underscored the importance of the collaborative process behind the document. “Developing the U.S. Plastics Pact’s EPR position paper was a collaborative process that brought in valuable perspectives from the public, private, and non-profit sectors on what representatives would like to see out of the future EPR programs,” Peck said. He added that policymakers can use the document as a practical resource grounded in actual experiences with EPR legislation across the country. For a landscape where EPR bills vary widely in scope and structure, such shared learnings are especially valuable.
Industry stakeholders echo this sentiment. Robert Flores, Vice President of Sustainability Operations and Advocacy – Americas at Amcor, noted that global packaging companies often encounter challenges caused by inconsistent regulatory approaches across regions. “As a global packaging company, we see firsthand how fragmented approaches can hold back progress,” he said. “EPR works best when every part of the value chain is engaged and contributing to balanced outcomes that are sustainable long-term.” His comments highlight the critical role of harmonization—not to impose one-size-fits-all policies, but to ensure that EPR systems operate predictably enough to drive meaningful investment in recycling infrastructure, packaging innovation, and long-term environmental improvements.
A major emphasis of the position paper lies in connecting the supply-side obligations of EPR—such as fees, system financing, and producer responsibilities—with demand-side policies that support a robust market for PCR materials. Without consistent end markets, recycling systems fail to deliver environmental or economic value. The USPP underscores that responsible end-market criteria and long-term targets are essential if policymakers want EPR programs to reinforce—not just regulate—the circular economy vision. By drawing the link between supply and demand, the paper helps ensure that upstream and downstream policies reinforce each other rather than operate in isolation.
Another key strength of the new guidance is its pragmatic framing. The USPP acknowledges that states vary widely in infrastructure, data availability, market conditions, and political dynamics. For this reason, the paper doesn’t prescribe rigid rules but instead outlines what an effective system should strive for, offering legislators a flexible but credible pathway to build policies tailored to their needs. Whether a state is developing its first EPR bill or refining an existing one, the document provides both foundational principles and actionable insights.
Jonathan Quinn, CEO of the U.S. Plastics Pact, noted the significance of achieving consensus on such a complex topic. “Anyone who has worked on EPR legislation understands how complex these issues can be,” Quinn said. “The fact that our Activators aligned around these principles is a testament to the strength of this network and our shared commitment to advancing circularity in the United States.” His statement reflects the broader mission of the USPP: to unite stakeholders in driving systemic change toward a more sustainable materials economy.
Ultimately, the release of this position paper marks an important milestone for the U.S. Plastics Pact and the wider sustainability community. As more states explore EPR legislation for packaging, the need for reliable, consensus-built, and technically grounded guidance continues to grow. The USPP’s new document aims to fill this gap by offering policymakers a roadmap informed by industry, government, and civil society alike—providing not just policy guidance, but a shared vision for a circular future where plastics are responsibly designed, recovered, and reused.
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