Textile & Packaging EPR Is Here: What Consumer Brands Need to Do Now (U.S. & Canada)

Businesses that manufacture, sell, ship, or distribute products must now determine whether their packaging and clothing is subject to emerging extended producer responsibility (EPR) requirements as EPR deadlines in various jurisdictions have arrived or are pending.

EPR is reshaping obligations for textiles and packaging across the United States and Canada. Laws now require producers to finance, and in many cases administer, end‑of‑life collection, recycling, reuse, and reporting, often via producer responsibility organizations (PROs). Key developments include California’s enacted textile EPR (SB 707), pending textile EPR bills in New York and Washington, and active packaging EPR programs in Oregon, Colorado, California, Maine, and Minnesota. Canada continues to expand full packaging EPR, notably in Ontario, Alberta, and British Columbia.  

U.S. Textile EPR (Selected Highlights)
California (Enacted): SB 707 requires textile/apparel producers to participate in a PRO and to implement an approved plan covering collection, repair, reuse, and recycling. Civil penalties for intentional violations can reach $50,000 per day once the plan is approved or by July 1, 2030, whichever occurs first.¹

New York (Pending): Senate/Assembly bills (e.g., S3217A/A6193A) would establish EPR for textiles with producer collection plans submitted to the Department of Environmental Conservation (DEC).²

Washington (Pending): HB 1420 proposes a statewide textile EPR program funded by manufacturers, with PRO membership and reporting requirements.³

U.S. Packaging EPR (Active Jurisdictions)
Oregon: Recycling Modernization Act (SB 582). Producer reporting began March 31, 2025, and the program commenced July 1, 2025; producers participate through a state‑approved PRO.⁴

Colorado: HB 22‑1355 requires producers to register (initial deadline was Oct. 1, 2024) and begin reporting in 2025–2026, with fees funding statewide recycling from 2026 onward; participation is generally through the state‑designated PRO.⁵

California: SB 54 establishes a single statewide PRO and imposes aggressive recyclability, source‑reduction, and recycling‑rate targets by 2032; major fee obligations ramp beginning in 2027.⁶

Maine: Rules effective Dec. 25, 2024; Maine will appoint a single Stewardship Organization; first comprehensive producer reports are anticipated in 2027 for 2026 data.⁷

Minnesota: Enacted in 2024; phased implementation under the Minnesota Pollution Control Agency, with PRO membership and statewide program milestones rolling out through the decade.⁸

Canada Packaging EPR (Selected Provinces)
Ontario: Blue Box Regulation requires producer registration, PRO contracts, and annual supply reporting (generally due May 31). Transition continues through 2025.⁹

Alberta: PPP EPR launched April 1, 2025, with regulator (ARMA) oversight fees and phased expansion (Phase 2 on Oct. 1, 2026); producers also pay PRO fees and must provide verified data.¹⁰

British Columbia: Recycle BC remains fully operational (province‑wide producer funding since 2014), with annual reporting and fee schedules administered via the PRO.¹¹

Compliance Playbook: What to Do This Quarter

• Map Coverage & Assign Owners: Inventory sales by jurisdiction and product (textiles vs. packaging). Assign Legal/Tax/Sustainability leads and a PRO liaison.
• Join the Right PROs: Confirm enrollment with the designated PROs (e.g., Circular Action Alliance for many U.S. packaging programs; Recycle BC/Circular Materials in Canada). Ensure all legal entities/brands are covered.
• Lock Reporting Calendars: Calendar March 31 / May 31 reporting touchpoints (jurisdiction‑specific). Add fee milestones (e.g., Oregon July cycles; Alberta oversight and PRO invoices).
• Stand-Up Data & Verification: Build BOM/weight data by SKU and jurisdiction. Alberta requires third‑party verification; expect more verification requirements elsewhere.
• Design for Compliance: Begin eco‑modulation (recyclable/reusable/compostable packaging; design for durability/repair in textiles) to lower fees and meet 2030–2032 targets.
• Track Legislative Risk: Monitor New York and Washington textile bills and adjust internal playbooks to mirror California SB 707 structures if enacted.

Conclusion
EPR obligations have arrived, with real registration, reporting, and fee requirements, and for textiles in California; significant penalties on the horizon. 

Organizations must centralize ownership, join the correct PROs, industrialize their data, and begin design‑for‑recycling/repair to stay ahead on both sides of the border.

By staying in front of and monitoring the extended producer responsibility requirements and deadlines, manufacturers and sellers of consumer goods will be prepared to face this convoluted regulations across various jurisdictions. 
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^{1 California Textile EPR (SB 707; Husch Blackwell / California Legislature / CA DTSC summaries: https://leginfo.legislature.ca.gov/ and practitioner summaries (e.g., Husch Blackwell).
2 New York Textile EPR (S3217A/A6193A)    New York State Senate, https://www.nysenate.gov/.
3 Washington Textile EPR (HB 1420), WA Legislature / WA Ecology, https://apps.leg.wa.gov/.
4 Oregon Recycling Modernization Act (SB 582) & DEQ, Oregon DEQ / Circular Action Alliance, https://www.oregon.gov/deq/ and https://circularactionalliance.org/. 
5 Colorado HB 22:1355 & CDPHE producer guidance, Colorado CDPHE / Circular Action Alliance / Holland & Hart alert, https://cdphe.colorado.gov/ and CAA & https://www.hollandhart.com/. 
6 California SB 54 (Packaging) & CalRecycle implementation, CalRecycle / Circular Action Alliance, https://calrecycle.ca.gov/ and https://circularactionalliance.org/. 
7 Maine 38 M.R.S. §2146; Ch. 428 rules; DEP program timeline, Maine DEP, https://www.maine.gov/dep/. 
8 Minnesota Packaging EPR (2024) & MPCA portal, Minnesota Pollution Control Agency, https://www.pca.state.mn.us/. 
9 Ontario Blue Box (O. Reg. 391/21); RPRA producer guidance, RPRA (Resource Productivity & Recovery Authority), https://rpra.ca/. 
10 Alberta EPR Regulation (Alta. Reg. 194/2022); ARMA guidance, Alberta Gov / ARMA / BLG bulletin, https://www.alberta.ca/ & https://www.albertarecycling.ca/ & https://www.blg.com/. 
11 British Columbia Recycling Regulation; Recycle BC, Recycle BC / BC Gov, https://recyclebc.ca/ and https://www.bclaws.gov.bc.ca/.}