Minnesota vs Saskatchewan EPR: Rules Compared
Last verified
Minnesota and Saskatchewan both run packaging EPR, but the rules differ. Saskatchewan exempts only producers below the lower revenue floor, CA$1,000,000 against $2,000,000 in Minnesota. Minnesota has the lower weight floor, 907.2 kg against 1 tonne in Saskatchewan. Both require producers to register. Both programmes set their first annual report for May 31.
Minnesota and Saskatchewan side by side
4 of 9 rows have a verified figure on each side of Minnesota and Saskatchewan; a cell reads “not yet published” when a side has none, and an exemption row reads “none recorded; see thresholds” when no exemption is on record.
| Measure | Minnesota | Saskatchewan | Stricter |
|---|---|---|---|
| Registration duty | Required | Required | Same |
| Producer organisation | one producer responsibility organisation | one producer responsibility organisation | Not comparable |
| Lowest revenue exemption | $2,000,000 | CA$1,000,000 | Saskatchewan |
| Lowest weight exemption | 907.2 kg | 1 tonne | Minnesota |
| First annual report date | May 31 | May 31 | Same |
| Published penalties | 1 published | not yet published | Not comparable |
| Report file | csv | csv | Not comparable |
| Paper fee, cheapest matched rate | not yet published | 31 cents per kilogram | Not comparable |
| Plastic fee, cheapest matched rate | not yet published | 113 cents per kilogram | Not comparable |
The lowest revenue exemption is $2,000,000 in Minnesota and CA$1,000,000 in Saskatchewan ($715,410 at the Bank of Canada 2025 annual average rate). Saskatchewan therefore reaches smaller sellers: a business with revenue between the two lines is exempt in Minnesota but still in scope in Saskatchewan.
The lowest weight exemption is 907.2 kg of packaging in Minnesota and 1 tonne in Saskatchewan, about 1.1 times as much in Saskatchewan as in Minnesota. A seller whose packaging falls between the two lines is exempt in Saskatchewan but counted in Minnesota.
Both programmes require a producer to register, in Minnesota and in Saskatchewan.
The first annual report date is the same on both sides, May 31.
Who runs the programme in Minnesota and Saskatchewan
Who collects and who the producer files with, in Minnesota and then Saskatchewan.
| Aspect | Minnesota | Saskatchewan |
|---|---|---|
| Regime | Minnesota packaging EPR law, Minnesota Statutes sections 115A.144 to 115A.1463 | Household Packaging and Paper Stewardship Program Regulations, 2023 |
| Regulator | Minnesota Pollution Control Agency | not yet published |
| Producers obligated | Yes | Yes |
| Registration | Required, Producer joins a PRO; the PRO registers with the MPCA | Required, SK Recycles producer portal |
| Producer organisation | one producer responsibility organisation: Circular Action Alliance; membership required | one producer responsibility organisation: SK Recycles; membership required |
| Who counts as the producer | primary: manufacturer, brand licensee, brand owner, importer | primary: brand owner, importer, seller; secondary: brand owner, importer, seller; tertiary: brand owner, importer, seller |
Both programmes organise producer responsibility the same way: one producer responsibility organisation. The practical differences between Minnesota and Saskatchewan therefore sit in thresholds, fees, dates and report formats rather than in whom a producer deals with.
What Minnesota and Saskatchewan cover, side by side
Each row below is one published feature of the two programmes; a cell reads “not yet published” when Minnesota or Saskatchewan has no verified entry for it in the dataset.
| Aspect | Minnesota | Saskatchewan |
|---|---|---|
| Materials covered | packaging, paper products | not yet published |
| Product classes covered | packaging, paper | not yet published |
| Excluded from scope | exempt materials | not yet published |
| Sales channels addressed | physical retail, remote sale, other distribution | not yet published |
| Producer duty: primary packaging | manufacturer; licensee; brand_owner; importer | brand_owner; importer; seller |
| Exemption 1 | A de minimis producer introduced under one ton or earned under $2,000,000 in global gross revenue in its most recent fiscal year. | Under 1,000 kg to Saskatchewan residents |
| Producer duty: secondary packaging | not yet published | brand_owner; importer; seller |
| Producer duty: tertiary packaging | not yet published | brand_owner; importer; seller |
| Reporting categories | not yet published | 19, material category |
| Exemption 2 | not yet published | Businesses under CAD 1 million in annual revenue |
Thresholds and exemptions in Minnesota and Saskatchewan
Every verified threshold Minnesota and Saskatchewan publish, as each states it.
| Place | Measure | Amount | Effect | Basis as published |
|---|---|---|---|---|
| Minnesota | packaging tonnage | 1 short ton | exempt below | covered material introduced, most recent fiscal year |
| Minnesota | revenue | $2,000,000 | exempt below | global gross revenue, most recent fiscal year |
| Saskatchewan | packaging weight | 1,000 kg | exempt below | annual supply to Saskatchewan residents |
| Saskatchewan | packaging weight | 5,000 kg | flat-fee band | 1,000 to 5,000 kg |
| Saskatchewan | revenue | CA$1,000,000 | exempt below | annual revenue |
Minnesota exemption: A de minimis producer introduced under one ton or earned under $2,000,000 in global gross revenue in its most recent fiscal year. It does not have to be applied for.
Saskatchewan exemption: Under 1,000 kg to Saskatchewan residents It does not have to be applied for.
Saskatchewan exemption: Businesses under CAD 1 million in annual revenue It does not have to be applied for.
Read the basis column first: the same amount can exempt a producer in one programme and only simplify its report in another.
The lowest revenue exemption is $2,000,000 in Minnesota and CA$1,000,000 in Saskatchewan ($715,410 at the Bank of Canada 2025 annual average rate). Saskatchewan therefore reaches smaller sellers: a business with revenue between the two lines is exempt in Minnesota but still in scope in Saskatchewan.
The lowest weight exemption is 907.2 kg of packaging in Minnesota and 1 tonne in Saskatchewan, about 1.1 times as much in Saskatchewan as in Minnesota. A seller whose packaging falls between the two lines is exempt in Saskatchewan but counted in Minnesota.
Fees per kilogram for shared materials
Saskatchewan publishes per-kilogram rates in the dataset; Minnesota does not. The rows therefore show Saskatchewan only. Until both sides publish per-kilogram rates for the same material class, a fee comparison between Minnesota and Saskatchewan would mean inventing a figure, and this page does not do that.
Saskatchewan: the 2027 fee schedule of SK Recycles, effective January 1, 2027, is the source of the per-kilogram rates used on this page.
Saskatchewan 2027: the category “Boxboard” is published at 31 cents per kilogram.
Saskatchewan 2027: the category “Plastic Film” is published at 113 cents per kilogram.
Saskatchewan 2027: the category “Clear Glass” is published at 30 cents per kilogram.
Deadlines in Minnesota and Saskatchewan
Each verified date, with the period it covers when one is given.
| Place | Kind | Date | Covers |
|---|---|---|---|
| Minnesota | registration | July 1, 2026 | not yet published |
| Minnesota | report | May 31, 2026 | not yet published |
| Minnesota | other | December 31, 2026 | not yet published |
| Minnesota | other | October 1, 2028 | not yet published |
| Minnesota | payment | February 1, 2029 | not yet published |
| Minnesota | payment | February 1, 2030 | not yet published |
| Minnesota | payment | February 1, 2031 | not yet published |
| Saskatchewan | report | May 31 | not yet published |
| Saskatchewan | payment | January 31 | fee year (the calendar year after the reporting year) |
| Saskatchewan | payment | April 30 | fee year (the calendar year after the reporting year) |
| Saskatchewan | payment | July 31 | fee year (the calendar year after the reporting year) |
| Saskatchewan | payment | October 31 | fee year (the calendar year after the reporting year) |
The first annual report date is the same on both sides, May 31.
Penalties in Minnesota and Saskatchewan
What each side has published; a side without an amount says so.
Minnesota penalty for violation of sections 115A.144 to 115A.1463: up to $25,000 per day.
Report formats in Minnesota and Saskatchewan
How the report file for Minnesota compares with the one for Saskatchewan.
| Aspect | Minnesota | Saskatchewan |
|---|---|---|
| Layout | Minnesota interim producer supply report by material class 2026-09-29 (interim, built from CAA guidance) | SK Recycles annual report Fee-year categories, reviewed 2026-09-29 |
| Recipient | Circular Action Alliance (Minnesota PRO) | SK Recycles |
| How it is submitted | CAA producer portal. The customer signs in and submits. | SK Recycles producer portal |
| File type | csv | csv |
| Encoding | utf-8 | utf-8 |
| Delimiter | , | , |
| Decimal separator | . | |
| Columns | 4 | 4 |
| Required columns | 4 of 4 | 4 of 4 |
| Weight unit | lb | kg |
| Period basis | calendar year | calendar year |
The two layouts share a file type and a delimiter, but each programme names its own columns and categories, so one file cannot be sent to both programmes. Each report is built from the same underlying measurements and exported separately.
Which to plan for first, Minnesota or Saskatchewan
Check the exemption thresholds before anything else. Saskatchewan reaches smaller sellers than Minnesota, so a seller that is exempt in Minnesota may still have to register in Saskatchewan.
Questions about comparing these two programmes
Is Minnesota or Saskatchewan stricter on packaging EPR?
Saskatchewan exempts only producers below the lower revenue floor, CA$1,000,000 against $2,000,000 in Minnesota. Minnesota has the lower weight floor, 907.2 kg against 1 tonne in Saskatchewan. Both require producers to register. Both programmes set their first annual report for May 31.
Do I register in both Minnesota and Saskatchewan?
Minnesota requires producers to register. Saskatchewan requires producers to register.
How do the fees per kilogram compare in Minnesota and Saskatchewan?
The dataset does not hold per-kilogram rates for the same material class on both sides, so this page does not compare fees.
Which deadline comes first, Minnesota or Saskatchewan?
The first annual report date is the same on both sides, May 31.
How these figures are made
Sources
- revisor.mn.gov: 115A.1441 retrieved
Original wording: requirements under sections 115A.144 to 115A.1463
Original wording: "Producer" means the following person responsible for compliance with requirements
Original wording: introduced less than one ton of covered material into this state
Original wording: earned global gross revenues of less than $2,000,000
Original wording: "De minimis producer" means a person that in their most recent fiscal year
Original wording: Packaging does not include exempt materials.
- circularactionalliance.org: minnesota retrieved
Original wording: the Minnesota Pollution Control Agency (MPCA) confirmed CAA’s registration to implement the state’s EPR program.
Original wording: Producers must be a member of a PRO that is registered with MPCA by July 1, 2025.
Original wording: CAA requires producers to provide simplified reporting by May 31, 2026
Original wording: December 31, 2026 Full Needs Assessment Due.
- web.archive.org retrieved
Original wording: the MPCA confirmed Circular Action Alliance (CAA) — a 501(c)(3) nonprofit, producer-led organization — as Minnesota’s initial PRO.
- revisor.mn.gov: 115A.1443 retrieved
Original wording: The producer responsibility organization must register with the commissioner by July 1, 2026, and each January 1 thereafter
- revisor.mn.gov: 115A.1451 retrieved
Original wording: By October 1, 2028, and every five years thereafter, a producer responsibility organization must submit a stewardship plan
- revisor.mn.gov: 115A.1455 retrieved
Original wording: no less than 50 percent of the net cost by February 1, 2029
Original wording: no less than 75 percent of the net cost by February 1, 2030
Original wording: no less than 90 percent of the net cost by February 1, 2031, and each year thereafter
- revisor.mn.gov: 115A.1462 retrieved
Original wording: civil penalty not to exceed $25,000 per day of violation
- skrecycles.ca: low volume producers retrieved
Original wording: Businesses supplying less than 1,000 kg of packaging and paper annually to Saskatchewan residents are exempt from registration and reporting requirements.
Original wording: Businesses supplying between 1,000 and 5,000 kg of material annually can file a simplified report and pay a flat fee.
- skrecycles.ca: are you a producer retrieved
Original wording: that business is the obligated producer as the brand holder.
Original wording: If a business or organization supplies packaging to consumers in Saskatchewan and is the brand owner resident in Canada
Original wording: Businesses with less than $1 million in annual revenue are also exempt.
- skrecycles.ca: reporting resources and guidebook retrieved
Original wording: Producers registered with SK Recycles are required to submit reports on the WeRecycle Portal by May 31
- sk-webmedia-assets-prod-shared-ca-central-1.s3.ca-central-1.amazonaws.com: SK Recycles Membership Agreement Dec11 2024 Final 2 retrieved
Original wording: each such instalment is due on January 31st, April 30th, July 31st and October 31st of the respective Fee Obligation Year
- skrecycles.ca: fees retrieved
Original wording: Newsprint 63
- Bank of Canada, FXAUSDCAD (annual average 2025) retrieved
- skrecycles.ca: SK Recycles 2027 Fee Schedule retrieved
Original wording: SK RECYCLES FEE SCHEDULE (CENTS/KG)
Original wording: Boxboard 31.00 31.00 0.0%
Original wording: Plastic Film 113.00 119.00 -5.0%
Original wording: GLASS Clear Glass 30.00 31.00 -3.2%
The free plan is enough to start. We estimate and prepare; you sign and submit.