Most Minnesota compliance talk is about PFAS. But Minnesota also passed a packaging EPR (extended producer responsibility) law in 2024: the Packaging Waste and Cost Reduction Act. It shifts the cost of recycling packaging onto the brands that put it on the market.
The program isn't fully live until 2029, but the data work starts now.
Key takeaways
- Minnesota is one of seven states with packaging EPR laws.
- The full program begins January 1, 2029.
- Producers report packaging weights by material and pay fees through a producer responsibility organization (PRO).
- Start collecting packaging data now; it's the same data other EPR states want.
What packaging EPR means
Under EPR, the "producer" of packaging pays for its collection and recycling, usually through a PRO. Fees are based on how much packaging you put on the market and what it's made of. Hard-to-recycle materials typically cost more.
Minnesota joins Maine, Oregon, Colorado, California, Maryland and Washington. See packaging EPR laws by state.
Who is a producer
Generally, the producer is:
- the brand owner of the product sold in the packaging, or
- if there's no brand owner in reach, the importer or first distributor into the state.
Covered materials include packaging, paper products and food serviceware sold or distributed in Minnesota. Small-producer exemptions exist; Minnesota's status is set by statute but may need to be shown if challenged. Check the current thresholds before assuming you're exempt.
Key dates
| Date | Milestone |
|---|---|
| 2025 | Producer registration began |
| July 1, 2026 | PRO registered with MPCA |
| May 31, 2026 | Simplified producer reports due (first cycle) |
| December 31, 2026 | Statewide needs assessment due |
| October 1, 2028 | PRO stewardship plan due |
| January 1, 2029 | Full program takes effect |
The Circular Action Alliance (CAA) is the approved PRO in Minnesota and several other states.
The data you'll need
For each product sold into Minnesota, per year:
- Packaging components: box, bag, insert, tissue, label, tape, poly bag, hangtag.
- Material type for each: paper/cardboard, plastic by resin (LDPE, PET, PP...), glass, metal, multi-material.
- Weight of each component.
- Units sold into the state.
- Recycled content, if known.
Multiply weight by units, sum by material, and you have your report. The hard part is getting accurate weights and materials from packaging suppliers, especially for trims and inner packs.
How this connects to PFAS
Minnesota already bans PFAS in food packaging. And packaging can carry PFAS through grease-resistant coatings or some inks. When you collect packaging specs for EPR, ask your packaging suppliers about PFAS at the same time. One request, two compliance needs.
Steps to take now
- Confirm producer status. Are you the brand owner? Do you meet any exemption?
- Register with the PRO if required.
- Build a packaging bill of materials for each SKU.
- Request packaging specs (material, weight, recycled content, PFAS) from every packaging supplier.
- Track units sold by state. Your e-commerce and wholesale systems need to report Minnesota volume.
- Reuse the data. Oregon, Colorado and California want the same breakdown.
Example: calculating one product's packaging
A brand sells a backpack in Minnesota. Its packaging per unit:
| Component | Material | Weight (g) |
|---|---|---|
| Poly bag | LDPE film | 18 |
| Hangtag | Paperboard | 6 |
| Hangtag string | PET | 1 |
| Shipping box (DTC) | Corrugated cardboard | 310 |
| Paper void fill | Kraft paper | 40 |
If it sells 2,000 units into Minnesota in a year, that's 36 kg of LDPE film, 12 kg of paperboard, 2 kg of PET, 620 kg of corrugated and 80 kg of kraft paper. Repeat for every SKU and you have your report. Fees will depend on each material's rate.
Small changes that lower EPR costs
EPR fees usually reward easier-to-recycle packaging. Common moves:
- Switch mixed-material packaging to single-material where possible.
- Cut empty space and oversized boxes.
- Replace hard-to-recycle films with recyclable alternatives.
- Increase recycled content where the program rewards it.
- Remove unnecessary inserts and tissue.
These changes help in every EPR state, not just Minnesota, including California's SB 54 program. See our SB 54 packaging guide.
Common questions
"We ship from a warehouse outside Minnesota. Are we covered?" Generally yes, if the product is sold or distributed into Minnesota.
"Our retailer repacks our products. Who reports?" It depends on who brands the final packaging. Check the definitions and your contract.
"Do hangtags and labels count?" Packaging definitions are broad. Expect most components that leave with the product to count.
"What if our packaging supplier doesn't know the weight?" Weigh samples yourself. A kitchen scale and a spreadsheet beat guesses.
Watch the timeline
Minnesota's program is the latest of the seven states to go fully live, but the needs assessment due December 31, 2026 will shape fees and rules. Follow MPCA and CAA updates through 2027 and 2028 so the 2029 start isn't a surprise.
Packaging EPR checklist
- Producer status confirmed for every product line
- Small-producer exemption checked
- PRO registration done where required
- Packaging BOM built for every SKU
- Material, resin, weight and recycled content collected from suppliers
- Minnesota unit sales pulled from all channels
- PFAS status asked for food-contact and coated packaging
- One data set designed to serve all EPR states
More questions
"Does Minnesota's EPR law cover paper products like catalogs?" Minnesota covers packaging, paper products and food serviceware. Check definitions for printed materials.
"Will fees be known before 2029?" Fee details come through the PRO and the program plan. Watch for the needs assessment and stewardship plan.
What to do this week
- Pick your top 20 SKUs by Minnesota volume. Packaging data for those covers most of your future fees.
- Weigh one unit of each packaging component for those SKUs. A digital scale and a shared spreadsheet are enough to start.
- Send one request to each packaging supplier for material, resin type, recycled content and PFAS status.
- Ask your e-commerce and wholesale teams for a units-by-state report. You'll need it for every EPR state.
Key terms
- EPR (extended producer responsibility): A policy that makes producers pay for packaging end-of-life.
- PRO (producer responsibility organization): The group producers join to report and pay fees.
- Producer: Usually the brand owner of the packaged product.
- Eco-modulation: Fee differences that reward easier-to-recycle packaging.
- Needs assessment: A statewide study that shapes the program, due in Minnesota by December 31, 2026.
The bottom line
Minnesota's packaging EPR program goes fully live in 2029, but the data work starts now. Confirm you're the producer, build packaging data by SKU, and design it so the same numbers serve Minnesota and every other EPR state.
How Secuabase helps
We collect packaging declarations and specs from your suppliers, including weights, materials and PFAS status, and turn them into a clean packaging data set you can reuse for Minnesota and every other EPR state.
For our first partners we run it free on one product line. Book a quick chat.
FAQ
When does Minnesota's program start?
The full program takes effect January 1, 2029, with registration and simplified reporting earlier.
Who is a producer?
Generally the brand owner, or the importer/distributor if the brand owner isn't reachable.
What data do I need?
Packaging weight by material type, per product, per year.
General information, not legal advice. Confirm with MPCA and your PRO. Facts checked October 2026.
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