Planning for 2024: Packaging EPR and the NLCRC’s Work

The states of Maine, Oregon, Colorado, and California are going through a policymaking process to implement their packaging Extended Producer Responsibility (EPR) laws, where, in most cases, have developed an estimated timeline for program implementation. This can include key dates to assign or join a Producer Responsibility Organization (PRO), and timelines for when to start paying EPR fees. For Brand Owners (Producers), this means that these should begin considering future compliance budget implications as the timeframes to join a PRO and pay EPR fees are getting closer. It is recommended that Brand Owners begin financial planning as soon as possible. 

The Petroleum Packaging Industry faces several significant challenges; one of the most significant is the implementation of new EPR laws in four states, which transfer the financial responsibility for product packaging recycling onto Brand Owners. EPR requires Producers to establish or join a Producer Responsibility Organization (PRO) that bolsters state recycling infrastructure by funding the PRO or state based on the weight of packaging sold. The Petroleum Packaging Industry is unique from most other industries due to the complications caused by residual product left in the packaging after use, including predominantly “landfill only” options for disposal across the US, the negative value of the packaging material, and the absence of a dedicated collection and recycling system to separate it from other waste streams.

Based on the NLCRC research and analysis, the impact of Extended Producer Responsibility (EPR) laws alone could have a potential impact of more than $250 MM per year in fees for the petroleum packaging industry within the next decade. The graph illustrates the potential impacts on the petroleum packaging industry of EPR over the next 10 years. 

The NLCRC is working on a solution to proactively manage EPR compliance for the petroleum and automotive industries that could potentially reduce the impacts of EPR fees. Reflecting on the current year, you are invited to read our blog posts to learn about the challenges at hand and how the NLCRC is working to address them:

• What to Expect in 2023 from Packaging EPR in the U.S.

• Early 2023 Progress On The Atlanta Lubricant Container Recycling Pilot

• Maine: An Example of Extended Producer Responsibility (EPR) Policy In The Making

• The NLCRC 2023 Priorities

• Oregon: An Example of Extended Producer Responsibility (EPR) Policy In The Making

• Colorado: An Example of Extended Producer Responsibility (EPR) Policy In The Making

• California: An Example of Extended Producer Responsibility (EPR) Policy In The Making 

• Progress On The Atlanta Lubricant Container Recycling Pilot

• Planning for EPR Compliance – What It Means to Brand Owners

• The NLCRC’s Actions Towards Increasing Recycling in the U.S.

The National Lubricant Container Recycling Coalition or “NLCRC” is an industry-led technical coalition established by a committed group of industry leaders in lubricant and associated plastic packaging manufacturing, focused on establishing solutions for post-consumer recovery and recycling of plastic lubricant containers.

NLCRC members include Berry Global, Castrol, Chevron, CKS Packaging Inc., Graham Packaging, Nexus Circular, Pennzoil - Quaker State Company, Petroleum Packaging Council, Plastipak Packaging, Safety-Kleen, and Valvoline. 

Connect with us on LinkedIn and Twitter. Reach out with questions or inquiries at hello@nationallcrc.com.