Short answer: Packaging EPR fees are generally calculated by multiplying the quantity of each packaging material you supply into a state by that program's rate for the material category, then applying state-specific adjustments such as eco-modulation. Rates are set by each program and can change annually, so any forecast is an estimate until the program invoices you.
The general model
Most programs follow the same basic logic, even though the details differ:
Reported quantity usually starts from your packaging data: component weight × components per unit × units supplied into the state during the data year. That is why packaging data quality drives fee accuracy.
Illustrative example
The example below uses invented rates and quantities purely to show the mechanics. It does not reflect any program's actual rates.
| Material category (illustrative) | Quantity supplied | Illustrative rate | Illustrative fee |
|---|---|---|---|
| Paperboard | 40,000 lb | $0.10 / lb | $4,000 |
| PET bottles | 15,000 lb | $0.30 / lb | $4,500 |
| Flexible plastic film | 3,000 lb | $0.80 / lb | $2,400 |
| Subtotal before adjustments | $10,900 |
In a real program, the categories would be the program's own list, and eco-modulation might raise or lower the charge for specific components.
Why rates and classifications vary
- Each program sets its own rates. Rates reflect the costs a program must fund in that state, which depend on its needs assessment, infrastructure and plan. In Oregon, for example, DEQ explains that fee rates are allocated based on producer supply and change annually.
- Material categories differ. Programs group materials differently, so the same component can land in different categories with different rates.
- Eco-modulation. Several programs adjust fees for attributes such as recyclability, recycled content or reuse. Colorado's regulations include eco-modulation, and Minnesota's law requires fees to vary based on factors including recyclability and postconsumer content.
- Program maturity. Early-stage programs may change methodology as they gather data, so year-over-year comparisons need care.
Scenario modeling
A forecast becomes useful for decisions when you can change the inputs. CertaRelay models scenarios such as:
- Switching a component material, for example a plastic tray to molded fiber.
- Lightweighting a bottle or carton.
- Adding recycled content where programs reward it.
- Entering a new state or channel.
- Rate changes in published program schedules.
Each scenario is labeled with its assumptions and the source of any rates used. When official rates are not yet published, the forecast says so and uses clearly marked placeholder assumptions.
How to prepare for 2027 fees
2027 is the year many brands will feel EPR fees across more than one program at once. Oregon and Colorado are already charging producers. In California, CalRecycle received Circular Action Alliance's producer responsibility plan on October 13, 2026 and has 75 days to review it, so California fee details depend on that plan. A practical preparation sequence:
- Lock your data year. Confirm which period each program's 2027 invoices will be based on, and make sure sales by state for that period are exportable.
- Close the biggest weight gaps first. Fees scale with weight, so prioritize your highest-volume SKUs and heaviest components.
- Get materials right. Misclassifying a component into a higher-cost category overstates fees; unsupported favorable classifications create risk.
- Build a range, not a point. Where official rates are final, use them. Where they are not, model low and high scenarios and label the assumptions.
- Put it in the budget. Give finance a documented estimate now and refresh it as programs publish final schedules.
- Look for redesign wins. Eco-modulation means packaging changes can move fees. Identify the few components that drive most of the cost.
Compliance-service fees versus producer fees
These are different things, and it is worth being explicit:
| Producer fees or dues | Compliance-service fees | |
|---|---|---|
| Who sets them | The state program or PRO | Your service provider |
| Who you pay | The PRO or program | The service provider |
| What they fund | Collection, recycling infrastructure, municipal reimbursement and program administration | The work of preparing your data and reports |
| How calculated | Reported quantities × program rates, with adjustments | Agreed scope |
CertaRelay's fees are compliance-service fees. CertaRelay does not set, collect or guarantee producer fees. See CertaRelay pricing.
CertaRelay recommendation
Forecast early, even with rough data. Finance teams need to budget for producer fees before programs invoice, and a forecast built on documented assumptions is far more useful than no number at all.