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.
Facts on this page were last verified against primary sources on August 23, 2026. The EPR Atlas is re-checked weekly; this stamp moves only when a verification pass actually runs, not when the site rebuilds.
<1 ton into MN OR <$2M global revenue (either qualifies; Minn. Stat. 115A.1441 subd. 13)
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.
What producers have to cover, and by when
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).
One test measured in Minnesota, the other measured globally
The de minimis rule is an either/or test: a producer qualifies by introducing less than one ton of covered material into Minnesota OR by earning global gross revenues under $2 million, and either condition alone is enough (Minn. Stat. 115A.1441, subd. 13). Note the tonnage test is measured on material introduced into Minnesota while the revenue test is global, and the statute says "one ton" without specifying metric or short.
Where rulemaking has got to
MPCA issued a formal notice of intent to develop rules on May 15, 2026; rulemaking will follow the December 2026 needs assessment.
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 Type
Rate / Metric Ton
Tier
Aluminum, cans
$139 (est.)
Tier 1
Clear PET (#1)
$579 (est.)
Tier 2-3
HDPE Natural (#2)
$208 (est.)
Tier 2-3
Steel
$231 (est.)
Tier 2-3
Uncoated Paper/Board
$185 (est.)
Tier 1
Corrugated
$185 (est.)
Tier 1
HDPE Pigmented (#2)
$740 (est.)
Tier 4
PP (#5)
$880 (est.)
Tier 4
Glass
$231 (est.)
Tier 2-3
LDPE Film / Mono-PE
$995 (est.)
Tier 4
PS Rigid (#6)
$2,245 (est.)
Tier 4
Expanded Polystyrene
$3,194 (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)
Recyclability / PCR / reuse credit (expected): not yet finalized
Fee Increases (Maluses)
Hard-to-recycle materials (expected): higher cost share, not yet finalized
Multiplier floor: Not established - stewardship plan due Oct 1, 2028
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.
Program Plan Status
Signaled
Plan submitted: No. No program plan has been filed; the implementing rules that will govern one are still being written.
Agency approved: Not applicable yet.
Where it stands: MPCA is at the pre-draft rulemaking stage. Its Request for Comments (docket sw-rule3-06a) closed July 24, 2026 and no draft rule text exists yet.
Next milestone: Statewide needs assessment due December 31, 2026. Producer fees do not begin until 2029, but the rules deciding how those fees are calculated are being written now.
Source: Minnesota Pollution Control Agency Request for Comments, docket sw-rule3-06a (closed July 24, 2026). Agency program page →
Reporting Deadlines and Key Dates
Jul 1, 2026
PRO must register with the MPCA commissioner (115A.1443 Subd. 1(a)); producers had to APPOINT a PRO by Jan 1, 2025
May 31, 2026
Simplified Supply Report due (CAA-set date, not statutory)
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)
Consumer packaging (all materials) and paper products. De minimis: <1 ton introduced into Minnesota OR <$2M global gross revenue; either alone qualifies (Minn. Stat. 115A.1441 subd. 13).
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 of covered material introduced into Minnesota OR global gross revenues <$2M. EITHER condition alone qualifies; the tests are joined by "or", not "and" (Minn. Stat. 115A.1441, subd. 13). CORRECTED 2026-08-03: this entry previously said both conditions had to be met and described Minnesota as stricter than the other states. The statute says otherwise. Note the tonnage test is measured on material introduced INTO MINNESOTA while the revenue test is global, and the statute says "one ton" without specifying metric or short.
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.
Hazardous Materials Packaging
Conditional, and claimed rather than automatic. Minn. Stat. 115A.1441 subd. 16(11) reaches OSHA Hazard Communication Standard products, but only where the hazard prevents the packaging from being waste reduced or made reusable, recyclable or compostable, “as determined by the commissioner”. The formal route at 115A.1453 subd. 6 is a producer request on a prescribed form, reviewed by the advisory board, approved only where a specific federal or state health and safety requirement prevents waste reduction, decided within 120 days, posted publicly, and expiring after two years. Unlike Maryland it is not limited to primary packaging. FIFRA packaging and refillable LPG containers are separately exempt at subd. 16(7) and (8).
Minnesota's de minimis is an EITHER/OR test, not a cumulative one (Minn. Stat. 115A.1441, subd. 13). A company at $1.9M global revenue is exempt on the revenue prong whatever its tonnage, and a company under one ton into Minnesota is exempt on the tonnage prong whatever its revenue. CORRECTED 2026-08-04: this note previously said both conditions had to be met, and gave a worked example that reached the opposite of the statutory answer.
Responsible Producer
Obligation follows a hierarchy: the brand owner whose brand is on the covered product; if the brand owner has no U.S. presence, the importer of record; if neither exists, the distributor or retailer that first sells the item into the state. Store-brand / private-label goods: the retailer whose brand appears is the producer. Licensed brands: the licensee that makes or sells is usually the producer unless the license assigns it.
MN: Standard hierarchy; confirm in the CAA portal. General framework; verify the statutory definition and your specific role before registering.
What You Report and Covered Materials
These attributes are the fee inputs, so instrument them at design time. CAA collects this once through its producer portal and maps it to each state you sell into; state-specific rules still apply. Retain supporting records (typically 3 to 5 years) to substantiate reports, exemptions, and credits.
Covered Material Category (CMC) for each component
Net weight per component, per unit (grams)
Units / volume placed on the state market in the reporting year
Post-consumer recycled (PCR) content %, with documentation
Recyclability designation (per the state list) and reuse / refill status
PCR / recycled content: No packaging PCR or source-reduction mandate yet (program pre-fee).
Source reduction: No source-reduction mandate yet; lighter packaging will lower future tonnage-based fees.
Toxics / substance limits: Minnesota applies the Toxics-in-Packaging heavy-metals limit and restricts PFAS (Amara's Law, phased); verify current food-packaging scope.
Sources: Minnesota Toxics in Packaging; Toxics in Packaging Clearinghouse member list (Minnesota is a member). Model the dollar impact of any design change in the EPR fee calculator; this is design guidance, not a fee estimate.
Statute and Rule Text
Statute: HF 3911 (2024), the Packaging Waste and Cost Reduction Act, codified at Minn. Stat. 115A.1455. Read the statute →
Implementing rule: No rule yet. MPCA rulemaking is at the pre-draft stage. The Request for Comments, docket sw-rule3-06a, closed July 24, 2026 and no draft rule text has been published. Read the rule →
Primary sources. Where the statute and an agency summary disagree, the statute and the adopted rule control.
Frequently Asked Questions
How is Minnesota's de minimis threshold different from other states?
Either condition alone qualifies. A producer is a de minimis producer in Minnesota if it introduced less than one ton of covered material into the state in its most recent fiscal year, OR if it earned global gross revenues of less than $2 million (Minn. Stat. 115A.1441, subd. 13). So a company at $1.9 million in revenue is exempt on the revenue test whatever its tonnage, and a company under one ton into Minnesota is exempt on the tonnage test whatever its revenue. The statute says "one ton" without specifying metric or short.
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 to CAA May 31, 2026, a CAA-set program date; Minn. Stat. 115A.1443 fixes only the July 1, 2026 PRO registration.
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.
Explore Minnesota Data in the Full EPR Atlas Hub
The EPR Atlas hub includes interactive tools to model your Minnesota EPR cost exposure and compare eco-modulation scenarios across all seven enacted states.