Short answer: Minnesota's Packaging Waste and Cost Reduction Act, signed in 2024, creates a phased packaging EPR program run through a Producer Responsibility Organization. Circular Action Alliance is registered as the PRO. The program is in its early phase: the Minnesota Pollution Control Agency (MPCA) released a draft 2026 needs assessment for comment, the first stewardship plan is expected in the 2027 to 2028 phase, and producer funding of program costs phases in from 2029.
What the Act is
The Packaging Waste and Cost Reduction Act (Minn. Stat. §§ 115A.144 to 115A.1463) requires producers of packaging, food packaging and paper products to fund and support improvements to Minnesota's reuse, recycling and composting systems. MPCA oversees implementation.
Program facts
Program phases, as published by MPCA
- 2025 to 2026 (Phase 1): PRO formation, advisory board appointment, service provider registration and needs assessments. MPCA accepted CAA's initial registration as the PRO. A draft 2026 Needs Assessment is open for public comment through November 13.
- 2027 to 2028 (Phase 2): Collection lists, statewide requirements and the PRO's first stewardship plan.
- 2029 to 2032 (Phase 3): Plan implementation, with PRO coverage of service and program costs phased in to at least 90% by 2031, plus annual reports.
- After January 1, 2032: Covered packaging, food packaging and paper products must be refillable, reusable, recyclable or compostable, supported by the relevant system.
The role of the PRO
In Minnesota, the PRO develops the stewardship plan, collects producer fees and reimburses service providers for covered costs. Producers meet their obligations through the PRO. Because CAA is also the PRO in several other states, many producers will deal with the same organization across programs, though each state's rules, categories and fees differ.
Eco-modulated fees
MPCA describes fees that must vary to encourage packaging that eliminates intentionally added toxic substances, reduces unnecessary material, increases reuse and postconsumer content, improves recyclability or compostability, and uses renewable or sustainable inputs. Each of those factors depends on component-level data you may not collect today, such as recycled content percentages.
Exemptions, at a high level
MPCA lists exemptions including business-to-business packaging that never reaches a consumer, FDA-regulated drugs and medical devices, certain animal drugs and devices, EPA-regulated pesticides, certain hazardous products, paint managed under an approved stewardship plan, infant formula and medical food, and specific paper categories. Confirm current scope with MPCA.
CertaRelay recommendation
Minnesota gives brands time. Use it to capture the attributes eco-modulation will reward or penalize, such as recycled content and material composition, before fees depend on them.
Producer data preparation
Producers should expect to report packaging quantities by material type and, for eco-modulation, packaging attributes. Starting the packaging foundation now avoids a rush when the stewardship plan sets reporting details.
What your team should prepare
- Units sold into Minnesota by SKU, or an allocation method from distributor data.
- Component-level packaging data with materials, formats and weights.
- Attributes relevant to eco-modulation: recycled content, recyclability, reuse.
- Whether any products may fall under listed exemptions.
How CertaRelay helps
- Extend your packaging foundation to capture Minnesota-relevant attributes.
- Track MPCA and PRO milestones and calendar registration and reporting.
- Model how eco-modulation and packaging changes may affect future fees.