Packaging EPR fees are turning material choice into a commercial decision

I have been reading Circular Action Alliance’s revised plan for California’s packaging law, SB 54, which creates an extended producer responsibility (EPR) program. It makes for interesting reading.

The proposed program got cheaper. As Packaging Dive reported, its projected 2027 budget fell from up to US$1.87 billion in the draft plan to about US$1.11 billion in the revision.

We saw a similar pattern in the UK. Policy signals intent, then implementation refines the detail. And that's how progress seems to be playing out in rapidly evolving global packaging regulations and reform.

The important development to note here is that California has put a price on plastic by tonne, material, and packaging format. The figures will continue to change as the system moves from planning to delivery.

California’s proposed fees put packaging format on the balance sheet

California’s proposed 2027 fees show how quickly material and format can affect cost. The following selected rates combine the base fee with the virgin-plastic adjustment, per metric tonne:

• Natural HDPE bottles: US$331
• Clear PET bottles: US$375
• PP tubs and trays: US$375
• PP bottles: US$463
• Multi-material pouches: US$661
• PP film: US$705
• PS and PVC film: US$772

These figures are preliminary. Circular Action Alliance’s 2027 California fee schedule also identifies reuse investment and Plastic Pollution Mitigation Fund charges, among other variables that can affect a producer’s final bill.

This points to the fundamentals of how EPR should work. Formats that are harder or more expensive to recover should carry more of the cost, and better choices should be encouraged. The schedule will need to evolve as collection, recovery infrastructure and technology improve.

Material selection now carries a direct financial consequence alongside the technical one.

The same component can have several price tags

Now compare California with the UK.

In the UK, producers can pay packaging EPR waste-disposal fees and (where applicable) a Plastic Packaging Tax on plastic packaging with less than 30% recycled content. The UK’s illustrative year-two amber fee for plastic is £455 per tonne. Add the current £228.82 per tonne Plastic Packaging Tax and the total is £683.82, or roughly US$915 using 21 October exchange rates.

California’s proposed clear PET rate is US$375 per tonne. PP film reaches US$705, and PS and PVC film reach US$772.

This is a directional comparison because the systems, scope and fee structures differ. But the commercial contrast is still striking.

Packaging EPR exposure is spreading across markets

California is only one state. Circular Action Alliance has also published 2027 fee schedules for Colorado and Oregon. Washington’s needs-assessment consultation closes on 30 October 2026 and Minnesota’s closes on 13 November 2026. Maine and Maryland have packaging EPR laws too.

Australia is still working through reform. The Australian Government says the existing co-regulatory arrangement remains in place while governments explore how packaging regulation should change.

A packaging component can attract a different fee in each regulated market where it is sold. And across thousands of SKUs and suppliers, differences in material, weight and jurisdiction can add up to substantial cost exposure.

This is why packaging compliance needs to be translated into clear operational decisions, with named owners, defined data fields and reliable evidence.

Five questions your packaging data needs to answer

To understand your level of exposure, I recommend starting with the following five questions:

1. What is each component made from?
2. What does it weigh?
3. Where is it sold?
4. Who supplied it and where was it made?
5. What evidence supports its recycled-content, recyclability and other credentials?

The answers support reporting, supplier conversations, fee modelling and packaging redesign. They also give decision-makers more options when fees, tax rates or market rules change.

Businesses that can answer these questions can compare scenarios earlier, focus effort on the components that matter the most and make better-informed packaging choices.

Packaging data continues to evolve into an increasingly valuable commercial asset.

Make the cost visible before it lands

If you want to see where your packaging data is strong, where evidence is missing and how a component can change cost across markets, book a Phantm walkthrough. We will show how structured packaging data supports fee modelling, compliance and better design decisions.