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Minnesota

Packaging Waste and Cost Reduction Act (HF 3911, 2024)

Registration Phase
PRO
Circular Action Alliance
Agency
Minnesota Pollution Control Agency (MPCA)
Exemption
Under $2M global revenue AND less than 1 ton of covered materials (BOTH must be true)
Fees
Fees begin January 2029. Commissioner sets fee amount by Oct 2028.
Penalties
Up to $25K/day (1st), $50K/day (2nd), $100K/day (3rd+)

Who is a “producer”?

Under HF 3911, a “producer” is determined in the following order of responsibility:

  1. 1Brand owner of the product sold in packaging in MN
  2. 2Licensee who sells under another's brand
  3. 3Importer of record for sale in MN
  4. 4Person who first distributes the item in or into MN

B2B packaging is explicitly exempt in Minnesota.

What's covered

Covered

  • ✓Packaging and packaging components
  • ✓Food packaging
  • ✓Paper products (including magazines, catalogs)
  • ✓Online purchases and shipments

Not Covered / Exempt

  • ✕De minimis producers (<$2M global AND <1 ton into state)
  • ✕B2B packaging (explicit exemption)
  • ✕Drugs/medical devices (FDA regulated)
  • ✕Infant formula, medical food, fortified nutritional supplements
  • ✕EPA-regulated pesticides/FIFRA products
  • ✕LPG containers designed to be refilled
  • + 5 more exemptions

Key Deadlines

DateWhat's DueStatus
Jul 1, 2025Join PRO deadlinePASSED
Jul 1, 2026Annual registration with commissionerUPCOMING
Dec 1, 2026Full needs assessmentUPCOMING
Invalid DateCollection lists + statewide requirements + first stewardship planFUTURE
Jan 1, 2029Fees begin — no producer may introduce covered materials unless under approved planFUTURE
Oct 1, 2028Commissioner provides written notice of registration fee amountFUTURE
Jan 1, 2032All packaging must be refillable, reusable, recyclable, or compostableFUTURE

Official Resources

Minnesota Pollution Control Agency (MPCA)pca.state.mn.us/air-water-land-climate/extended-producer-responsibility-for-packagingCAA Minnesota Portalcircularactionalliance.org/circular-action-alliance-minnesota

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