The U.S. Plastics Pact (USPP) on Wednesday released its first-ever policy position paper on Extended Producer Responsibility (EPR), offering what it calls “a clear, consensus-built” framework to guide policymakers as states consider EPR legislation for plastic packaging. 

“Developed through extensive engagement across the entire packaging value chain, the paper outlines six key policy levers that support effective, equitable, and implementable EPR programs,” USPP said in a statement.

The paper reflects months of work by brands, retailers, manufacturers, recyclers, NGOs, government entities, and technical experts. It draws on a value-chain survey, a hybrid workshop on EPR fundamentals, and multiple rounds of review by U.S. Plastics Pact members (called “Activators”), whose feedback shaped the final guidance. 

“There is no shortage of EPR guidance in the marketplace — but what makes this one different is the process behind it,” said Megan O’Brien, program manager for reporting and special projects at the USPP. “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.”

The position paper identifies six policy levers — Funding Model, Funding System Design, Fee-Setting & Eco-modulation, Performance Targets, Responsible End Markets, and Covered Materials — that states can use to build structured, harmonized EPR systems while retaining flexibility to address local infrastructure, data, and market realities. 

Drawing on USPP’s Roadmap 2.0 and widely recognized guidance from the Ellen MacArthur Foundation, the paper emphasizes clear definitions, transparent and responsible end-market criteria, achievable initial requirements, and mechanisms to increase ambition over time. 

“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,” said Preston Peck, Senior Sustainability Analyst with the City of Tacoma, Washington. “We hope that this document can provide legislators and advocates with guidance on best practices, lessons learned, and other policy considerations from Pact members’ experience with EPR policy development and implementation across the U.S.”

“As a global packaging company, we see firsthand how fragmented approaches can hold back progress,” said Robert Flores, Vice President of Sustainability Operations and Advocacy - Americas at Amcor. “EPR works best when every part of the value chain is engaged and contributing to balanced outcomes that are sustainable long-term.”

The position paper underscores the link between supply-side EPR obligations and demand-side policies needed to strengthen post-consumer recycled content (PCR) markets — a critical element of a functioning circular system. 

The full EPR policy position paper is available here.