Active Program

Minnesota Packaging EPR: Producer Compliance Guide

Minnesota's HF 3911 (2024) -- the Packaging Waste and Cost Reduction Act -- uses a distinctive cost-share model rather than a direct fee-per-ton structure. Producers are required to cover at least 50% of net recycling costs by February 1, 2029, 75% by February 1, 2030, and 90% by February 1, 2031 (confirmed in MN Statutes 115A.1455, Subd. 4). Administered by MPCA through the Circular Action Alliance (CAA), the program has a unique de minimis rule: both conditions must be met simultaneously -- less than 1 metric ton placed on the Minnesota market AND less than $2 million in global revenue. All other states use an either/or standard. MPCA issued a formal notice of intent to develop rules on May 15, 2026; rulemaking will follow the December 2026 needs assessment.

Governing Law
HF 3911 - Packaging Waste and Cost Reduction Act (2024)
Fee Start
Feb 1, 2029 (50% cost-share)
Max Penalty
MPCA enforcement (TBD)
Administering Agency
Minnesota MPCA
PRO / Administrator
Circular Action Alliance
De Minimis
<1 ton AND <$2M revenue (both must be met)
Fees are not yet active. Amounts shown are projections based on Oregon's published 2025-26 rates at the Minnesota program multiplier (1.05x). Actual rates will be set when the program plan is approved.

Fee Schedule by Material

Base rates before eco-modulation. Final fee = Tonnage x Rate x Eco-Modulation Multiplier. All amounts are projections; actual rates set upon program plan approval.

Material / Packaging TypeRate / Metric TonTier
Aluminum, cans $126 (est.) Tier 1
Clear PET (#1) $525 (est.) Tier 2-3
HDPE Natural (#2) $189 (est.) Tier 1
Steel $210 (est.) Tier 2-3
Uncoated Paper/Board $168 (est.) Tier 1
Corrugated $168 (est.) Tier 1
HDPE Pigmented (#2) $672 (est.) Tier 4
PP (#5) $798 (est.) Tier 4
Glass $210 (est.) Tier 2-3
LDPE Film / Mono-PE $903 (est.) Tier 4
PS Rigid (#6) $2,037 (est.) Tier 4
Expanded Polystyrene $2,898 (est.) Tier 4

Eco-Modulation Factors

○ SpeculativeProjected/estimated. Eco-modulation rules are not yet finalized in this state.

Source: HF 3911 (2024) / MN Stat. 115A.1455. CAA selected Feb 18, 2025. Eco-mod set in the stewardship plan (PRO plan due Oct 1, 2028); not yet established.

Eco-modulation adjusts fees based on packaging design and recyclability attributes.

Fee Reductions (Bonuses)

Expected (not finalized): credit tied to recyclability/recycled content/reuse

Fee Increases (Maluses)

Expected (not finalized): higher cost share for hard-to-recycle materials

Multiplier floor: Not established - stewardship plan due Oct 1, 2028

ℹ️
SPECULATIVE for eco-mod. Cost-share model ramps: 50% of net recycling costs by Feb 1, 2029; 75% by Feb 1, 2030; 90% by Feb 1, 2031 (MN Stat. 115A.1455). Eco-mod criteria follow the CAA harmonized approach once the stewardship plan is approved; specific factors/rates not yet established.

Key Dates and Timeline

Jul 1, 2025
Producer registration required
May 31, 2026
Simplified Supply Report due
May 15, 2026
MPCA issues formal notice of intent to develop EPR rules
Dec 31, 2026
MPCA needs assessment complete
Oct 1, 2028
PRO submits stewardship plan to Advisory Board
Jan 1, 2029
Producer PRO agreements required; prohibition on sale without agreement
Feb 1, 2029
50% cost-share - first fee payments due (115A.1455)
Feb 1, 2030
75% cost-share milestone
Feb 1, 2031
90% cost-share milestone - sustained annually thereafter

Covered Products Scope

Consumer packaging (all materials) and paper products. De minimis: <1 ton AND <$2M (both required). Excludes: B2B tertiary packaging, pharmaceutical/medical packaging, DOT-regulated hazmat containers.

Exemptions and Exclusions

The following categories may be fully or partially exempt from producer obligations in Minnesota. Verify applicability with the CAA producer portal or Minnesota MPCA before excluding any materials from supply reports.

De Minimis (Small Producer)
<1 ton AND <$2M global revenue - BOTH conditions must be met. This is stricter than other states where either/or qualifies. Companies near either threshold should model carefully.
B2B / Tertiary Packaging
Tertiary/transport packaging used exclusively B2B (never reaching consumers) excluded
Medical Device and Pharmaceutical
Packaging for FDA-regulated medical devices excluded. Packaging for infant formula excluded.
Agricultural Packaging
Certain agricultural packaging covered under separate MDA (Minnesota Dept. of Agriculture) programs. Confirm specific scope with MPCA.
Minnesota's de minimis requires BOTH tonnage AND revenue thresholds - not either/or. A company at $1.9M revenue but 2 tons placed on market is NOT exempt.

Frequently Asked Questions

How is Minnesota's de minimis threshold different from other states?
Minnesota requires BOTH conditions simultaneously: less than 1 metric ton placed on the Minnesota market AND less than $2 million in global revenue. All other enacted states use an either/or standard. A company at $1.9 million revenue but 2 tons placed on the market is NOT exempt in Minnesota.
When do Minnesota EPR fees begin?
Minnesota's first fee obligation (50% cost-share of net recycling costs) begins February 1, 2029, per MN Statutes 115A.1455, Subd. 4. The cost-share ramps to 75% by February 1, 2030 and 90% by February 1, 2031.
What type of supply report does Minnesota require?
Minnesota currently requires a Simplified Supply Report showing aggregated weight by material category -- not SKU-level detail. The 2025 supply report was due May 31, 2026.
What is Minnesota's PRO structure?
Minnesota's EPR program is administered through the Circular Action Alliance. Producer-PRO agreements are required by January 1, 2029 -- a company without an agreement by that date cannot legally sell covered products in Minnesota.