How to Reduce EPR Fees — 7 Strategies
EPR fees are eco-modulated — non-recyclable materials cost 2–5× more per pound than recyclable ones. Material selection has the biggest financial impact, more than any credit or bonus. Here are 7 strategies ranked by savings.
These strategies are ranked by estimated impact, starting with the biggest savings.
Material selection — pick a lower-fee category
55–81%Switching from a high-fee material category to a lower-fee category saves more than any eco-modulation bonus. Non-recyclable materials cost 2–5× more per pound than recyclable ones. Switching to recyclable rigid plastic saves 55–81% (CO: 67–81%, OR: 64–84%, CA: 35–73%).
How to implement
- ▸Audit your packaging portfolio — identify every SKU in a high-fee category
- ▸Prioritize high-volume products first — small changes at scale have the biggest impact
- ▸Work with your supplier on mono-material alternatives for multi-material SKUs
- ▸Test for product compatibility before switching
Design for recyclability
Category shiftRemove problematic laminations, foils, adhesives, and coatings that push packaging into non-recyclable categories. Multi-material composites (plastic + foil + paper) are classified as non-recyclable and pay the highest rates. Even small design changes can shift a package from non-recyclable to recyclable — dropping the per-pound rate dramatically.
How to implement
- ▸Identify laminated, coated, or multi-layer SKUs in your portfolio
- ▸Replace foil lamination with mono-material alternatives where possible
- ▸Switch to water-based adhesives and coatings that don't contaminate recycling streams
- ▸Standardize to industry-standard formats that stay on the MRL (Minimum Recyclable List)
- ▸Validate with your recycler that the redesigned format is actually recyclable
Lightweight your packaging
1:1 directEPR fees are calculated per pound of packaging material. Less weight = fewer pounds reported = lower fees. A 10% weight reduction = 10% fee reduction. No eco-modulation needed — it's a direct 1:1 savings that applies in every state.
How to implement
- ▸Identify over-packaged SKUs (excess void fill, oversized boxes, heavy closures)
- ▸Test lighter-weight alternatives without sacrificing product protection
- ▸Focus on heaviest materials first (glass, steel, corrugated)
- ▸Even small per-unit reductions compound across thousands of SKUs
Increase PCR content
Future-proofs + CO: −5%Higher post-consumer recycled (PCR) content shifts packaging into lower-rate recyclable categories and supports impact-reduction claims. In Colorado, materials with proven high recycling rates qualify for a −5% High Recycling Rate Bonus. In Oregon, PCR increases are a qualifying activity under environmental performance incentives. Increasing PCR now future-proofs your packaging for upcoming state programs.
How to implement
- ▸Check if your packaging materials are on the CAA Minimum Recyclable List
- ▸Use materials with documented high recycling rates (PET, HDPE, corrugated)
- ▸Set PCR targets — even 10% PCR content can improve category classification
- ▸Document recycling rates and PCR percentages for CAA reporting
Reuse & refill systems
Potentially largest incentivePotentially the largest eco-modulation incentive, but also the most difficult to implement. Oregon's approved program rewards transitions from single-use packaging to reusable/refillable systems. California requires at least 10% of source reduction from reuse/refill or elimination. Best suited for high-volume SKUs where infrastructure investment pays off.
How to implement
- ▸Identify high-volume SKUs where reuse/refill is feasible (household products, beverages, CPG)
- ▸Start with pilot programs at key retailers rather than full rollout
- ▸Design for durability — reusable packaging must survive multiple trips
- ▸Track return/refill rates for CAA reporting and eco-modulation qualification
- ▸California requires a written Source Reduction Plan — reuse/refill counts toward the 10% minimum
Avoid Detriments malus (Colorado)
+5% avoidedColorado's published dues schedule includes a Detriments malus of +5% — an automatic surcharge on materials that disrupt recycling processes (like PVC, certain additives). Avoiding these materials dodges the surcharge on top of the already-higher non-recyclable base rate.
How to implement
- ▸Check the CAA Detriments list for materials you use
- ▸Audit packaging for PVC, contaminating additives, and flagged materials
- ▸Work with suppliers to replace detriment materials
- ▸Document material changes for CAA reporting
Avoid Prop 65 chemicals (California)
TBDCalifornia's SB 54 is expected to include a malus for packaging containing Proposition 65 chemicals (PFAS, vinyl, etc.). The specific surcharge has not yet been published by CAA — expected with the program plan in Oct 2026. Removing these chemicals now prepares you for when it takes effect.
How to implement
- ▸Audit all packaging materials for Prop 65 listed chemicals
- ▸Focus on inks, adhesives, and plasticizers first — these are the most common sources
- ▸Work with suppliers to find alternative formulations
- ▸Document all changes for CAA reporting
See your potential savings
Use the fee calculator to see exactly how much recyclable vs. non-recyclable materials cost in each state.
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