Minnesota vs Spain EPR: Rules Compared
Last verified
Minnesota and Spain both run packaging EPR, but the rules differ. Both require producers to register. Spain asks for its first annual report earlier, on March 31 against May 31 in Minnesota. Every figure below links to its primary source.
Minnesota and Spain side by side
2 of 9 rows have a verified figure on each side of Minnesota and Spain; 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 | Spain | Stricter |
|---|---|---|---|
| Registration duty | Required | Required | Same |
| Producer organisation | one producer responsibility organisation | more than one producer responsibility organisation | Not comparable |
| Lowest revenue exemption | $2,000,000 | none recorded; see thresholds | Not comparable |
| Lowest weight exemption | 907.2 kg | none recorded; see thresholds | Not comparable |
| First annual report date | May 31 | March 31 | Spain |
| Published penalties | 1 published | 3 published | Not comparable |
| Report file | csv | csv | Not comparable |
| Paper fee, cheapest matched rate | not yet published | 0.117 EUR/kg | Not comparable |
| Plastic fee, cheapest matched rate | not yet published | 0.530 EUR/kg | Not comparable |
Both programmes require a producer to register, in Minnesota and in Spain.
The earliest annual report date is May 31 in Minnesota and March 31 in Spain, 61 days apart. Spain leaves less time to prepare, so its data has to be ready first.
Who runs the programme in Minnesota and Spain
Who collects and who the producer files with, in Minnesota and then Spain.
| Aspect | Minnesota | Spain |
|---|---|---|
| Regime | Minnesota packaging EPR law, Minnesota Statutes sections 115A.144 to 115A.1463 | Royal Decree 1055/2022 on packaging and packaging waste, under Law 7/2022 on waste and contaminated soils |
| Regulator | Minnesota Pollution Control Agency | Ministry for the Ecological Transition (MITECO), Directorate-General for Environmental Quality and Assessment |
| Producers obligated | Yes | Yes |
| Registration | Required, Producer joins a PRO; the PRO registers with the MPCA | Required, Packaging section of the Register of Product Producers (Registro de Productores de Productos) |
| Producer organisation | one producer responsibility organisation: Circular Action Alliance; membership required | more than one producer responsibility organisation: Ecoembes, Ecovidrio; membership required |
| Transfer of responsibility | not yet published | Allowed |
| Who counts as the producer | primary: manufacturer, brand licensee, brand owner, importer | primary: manufacturer or brand owner, importer, first distributor; secondary: manufacturer or brand owner, importer, first distributor; service: manufacturer or brand owner, importer, first distributor; shipping: online marketplace seller, manufacturer or brand owner; tertiary: manufacturer or brand owner, importer, first distributor |
The two programmes are organised differently. Minnesota uses one producer responsibility organisation; Spain uses more than one producer responsibility organisation. For a seller in both, that usually means two different counterparties, two different sign-up routes and two different sets of terms to read before the first report is due.
What Minnesota and Spain cover, side by side
Each row below is one published feature of the two programmes; a cell reads “not yet published” when Minnesota or Spain has no verified entry for it in the dataset.
| Aspect | Minnesota | Spain |
|---|---|---|
| Materials covered | packaging, paper products | all packaging materials, plastic, paper and cardboard, metal, glass, wood, other |
| Product classes covered | packaging, paper | household packaging, commercial and industrial packaging, service packaging |
| Excluded from scope | exempt materials | not yet published |
| Sales channels addressed | physical retail, remote sale, other distribution | domestic producers, producers established in other Member States or third countries via an authorised representative, e-commerce platforms acting as producer where no representative is appointed |
| Producer duty: primary packaging | manufacturer; licensee; brand_owner; importer | manufacturer_brand_owner; importer; first_distributor |
| 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. | not yet published |
| Producer duty: secondary packaging | not yet published | manufacturer_brand_owner; importer; first_distributor |
| Producer duty: tertiary packaging | not yet published | manufacturer_brand_owner; importer; first_distributor |
| Producer duty: shipping packaging | not yet published | online_marketplace_seller; manufacturer_brand_owner |
| Producer duty: service packaging | not yet published | manufacturer_brand_owner; importer; first_distributor |
| Published targets | not yet published | recycling rate, all packaging waste 65% by 2025-12-31; recycling rate, all packaging waste 70% by 2030-12-31 |
Thresholds and exemptions in Minnesota and Spain
Every verified threshold Minnesota and Spain 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 |
| Spain | packaging weight | 10 tonnes per calendar year | reduced duty | packaging made available for the first time in the Member State |
| Spain | packaging weight | 15 tonnes per year | reduced duty | packaging placed on the market |
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.
Read the basis column first: the same amount can exempt a producer in one programme and only simplify its report in another.
Fees per kilogram for shared materials
Spain publishes per-kilogram rates in the dataset; Minnesota does not. The rows therefore show Spain only. Until both sides publish per-kilogram rates for the same material class, a fee comparison between Minnesota and Spain would mean inventing a figure, and this page does not do that.
Spain: the 2027 fee schedule of Ecoembes / Ecovidrio, effective January 1, 2027, is the source of the per-kilogram rates used on this page.
Spain 2027: the category “Paper and cardboard, non-SUP” is published at 0.117 EUR/kg.
Spain 2027: the category “Plastic bags (UNE standard)” is published at 0.530 EUR/kg.
Spain 2027: the category “Glass (weight factor)” is published at 0.03761 EUR/kg.
Deadlines in Minnesota and Spain
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 |
| Spain | report | June 1 | the previous calendar year |
| Spain | other | August 12, 2026 | not yet published |
| Spain | report | March 31 | the previous calendar year |
The earliest annual report date is May 31 in Minnesota and March 31 in Spain, 61 days apart. Spain leaves less time to prepare, so its data has to be ready first.
Penalties in Minnesota and Spain
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.
Spain penalty for very serious infringement: €100,001 to €3,500,000 per infringement.
Spain penalty for serious infringement: €2,001 to €100,000 per infringement.
Spain penalty for minor infringement: up to €2,000 per infringement.
Report formats in Minnesota and Spain
How the report file for Minnesota compares with the one for Spain.
| Aspect | Minnesota | Spain |
|---|---|---|
| Layout | Minnesota interim producer supply report by material class 2026-09-29 (interim, built from CAA guidance) | Spain packaging declaration (working layout) Working layout, sources reviewed 2026-11-04 |
| Recipient | Circular Action Alliance (Minnesota PRO) | Ministerio para la Transición Ecológica: Registro de Productores de Producto, sección de envases |
| How it is submitted | CAA producer portal. The customer signs in and submits. | Registro de Productores de Productos (MITECO), packaging section; registry entry. The customer signs in and submits. |
| 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 Spain
Plan around the earlier report date first. Spain asks for its first annual report on March 31, before Minnesota, so its data has to be ready first.
Questions about comparing these two programmes
Is Minnesota or Spain stricter on packaging EPR?
Both require producers to register. Spain asks for its first annual report earlier, on March 31 against May 31 in Minnesota.
Do I register in both Minnesota and Spain?
Minnesota requires producers to register. Spain requires producers to register.
How do the fees per kilogram compare in Minnesota and Spain?
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 Spain?
The earliest annual report date is May 31 in Minnesota and March 31 in Spain, 61 days apart. Spain leaves less time to prepare, so its data has to be ready first.
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
- boe.es: act (2022) (buscar) retrieved
Original wording: se crea la sección de envases en el Registro de Productores de Productos
Original wording: a través de la Dirección General de Calidad y Evaluación Ambiental
Original wording: se obliga a todos los envasadores a inscribirse y a remitir anualmente información
Original wording: se inscribirán en la sección de envases del Registro de Productores de Productos
Original wording: deberán designar a una persona física o jurídica en territorio español como representante autorizado
Original wording: un certificado de pertenencia a un sistema individual o colectivo de responsabilidad ampliada del productor
Original wording: menos de 15 toneladas de envases al año
Original wording: antes del 31 de marzo del año siguiente
- eur-lex.europa.eu: oj retrieved
Original wording: makes available for the first time on the territory of another Member State, directly to end users
Original wording: a quantity of packaging, including packaging of packaged products, of less than 10 tonnes during one calendar year
Original wording: of Annex IX to the competent authority responsible for the register, by 1 June for each full preceding calendar year.
Original wording: It shall apply from 12 August 2026.
Original wording: by 31 December 2030, a minimum of 70 % by weight of all packaging waste generated
- boe.es: act (2022) (buscar) retrieved
Original wording: Multa desde 100.001 euros hasta 3.500.000 euros
- ecoembesempresas.com: Ecoembes Precios2027 retrieved
Original wording: Precios 2027 Envases domésticos
Original wording: Envases no SUP 0, 117
Original wording: Bolsas UNE 0,530
Original wording: 0,03761 0,00533 + €/ud
The free plan is enough to start. We estimate and prepare; you sign and submit.