EPR Resources
EPR & Packaging Compliance
An Action Plan for Automotive Aftermarket Companies
Extended Producer Responsibility, or EPR, laws are changing who pays for packaging recovery and recycling. Instead of municipalities carrying the full cost, certain states now require producers to register, report packaging data, and fund recycling programs.
For automotive aftermarket companies, this matters because the industry sells through layered supply chains. A product may be manufactured by one company, imported by another, privately labeled by a distributor, sold through a retailer, and shipped into multiple states. That makes one question especially important:
Who is the obligated producer?
California, Colorado, and Oregon are active now, and aftermarket companies should be assessing their exposure before assuming another party is responsible. California covered materials include single use packaging and single use plastic food service ware, Colorado requires companies selling products in packaging and paper products to fund a statewide recycling system, and Oregon requires producers of packaging, paper, and food serviceware to register, report data, and pay fees through an approved PRO.
Why this matters for the aftermarket
EPR can apply to common aftermarket scenarios, including:
Private label parts and accessories
Imported products sold under your brand
Products packaged for retail shelves
Products sold through distributors or ecommerce channels
Replacement parts, tools, chemicals, fluids, and accessories
Packaging used for multipacks, kits, cartons, mailers, inserts, and protective materials
Petroleum and automotive product packaging in Colorado
The risk is not just whether your company manufactures the product. The risk is whether your company is considered the producer under each state’s law.