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Illinois EPR Guide
Packaging Extended Producer Responsibility Act (HB 4064 / SB 1817 (stalled))
PRO
TBD — none enacted yet
Agency
Illinois EPA
Exemption
Under $2M global revenue OR less than 1 ton into state (EITHER qualifies) — HB 4064 de minimis definition
Fees
Fees not yet set — bill pending
Penalties
TBD — bill pending
Who is a “producer”?
Under HB 4064 / SB 1817 (stalled), a “producer” is determined in the following order of responsibility:
- 1Brand owners selling packaged products into Illinois
- 2Licensees and importers
B2B packaging is explicitly exempt in Illinois.
What's covered
Covered
- ✓Packaging and paper products sold or supplied in the state (no consumer-facing limiter in the definition)
- ✓Plastic food service ware
- ✓Shipping/tertiary packaging (all channels — exemption only for the B2B production loop)
Not Covered / Exempt
- ✕Beverage containers under IL bottle bill (if enacted)
- ✕Small producers (<$2M global OR <1 ton — HB 4064 de minimis)
- ✕Packaging that stays in the B2B production loop (distributes to another producer, then to a commercial/business entity for production, and nowhere else) — HB 4064 exempt clause (14)
Special Exemptions
Illinois has more generous exemption criteria than other states. A producer is exempt if ANY of the following apply:
- ✓De minimis: <$2M global gross revenue OR <1 ton introduced (HB 4064)
Key Deadlines
| Date | What's Due | Status |
|---|---|---|
| Dec 1, 2026 | Statewide Recycling Needs Assessment report due to the legislature (Eunomia study, SWIFR-funded) | UPCOMING |
| Jan 1, 2027 | 2027 legislative session begins — HB 4064 expected to advance after the needs assessment | FUTURE |
| May 1, 2027 | Projected session adjournment — earliest window for EPR bill passage | FUTURE |
Official Resources
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