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Minnesota vs United Kingdom EPR: Rules Compared

Last verified

Minnesota and United Kingdom both run packaging EPR, but the rules differ. Both require producers to register. United Kingdom asks for its first annual report earlier, on April 1 against May 31 in Minnesota. Every figure below links to its primary source.

Paired bars comparing how many verified thresholds, deadlines and penalties Minnesota and United Kingdom publish, and how many columns their report layouts hold.Minnesota / United Kingdom (published items): Thresholds: Minnesota 2, United Kingdom 3; Deadlines: Minnesota 7, United Kingdom 6; Penalties: Minnesota 1, United Kingdom 0; Report columns: Minnesota 4, United Kingdom 15MinnesotaUnited Kingdompublished items051015Thresholds23Deadlines76Penalties10Report columns415
Source: Minnesota and United Kingdom primary sources, retrieved 2026-11-05

Minnesota and United Kingdom side by side

2 of 9 rows have a verified figure on each side of Minnesota and United Kingdom; 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.

Minnesota and United Kingdom: the measures both programmes publish
MeasureMinnesotaUnited KingdomStricter
Registration dutyRequiredRequiredSame
Producer organisationone producer responsibility organisationproducer compliance schemesNot comparable
Lowest revenue exemption$2,000,000none recorded; see thresholdsNot comparable
Lowest weight exemption907.2 kgnone recorded; see thresholdsNot comparable
First annual report dateMay 31April 1United Kingdom
Published penalties1 publishednot yet publishedNot comparable
Report filecsvcsvNot comparable
Paper fee, cheapest matched ratenot yet published196 GBP/tonneNot comparable
Plastic fee, cheapest matched ratenot yet published423 GBP/tonneNot comparable

Both programmes require a producer to register, in Minnesota and in United Kingdom.

The earliest annual report date is May 31 in Minnesota and April 1 in United Kingdom, 60 days apart. United Kingdom leaves less time to prepare, so its data has to be ready first.

Who runs the programme in Minnesota and United Kingdom

Who collects and who the producer files with, in Minnesota and then United Kingdom.

Minnesota and United Kingdom: how each programme is set up
AspectMinnesotaUnited Kingdom
RegimeMinnesota packaging EPR law, Minnesota Statutes sections 115A.144 to 115A.1463Extended producer responsibility (EPR) for packaging, under the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024
RegulatorMinnesota Pollution Control AgencyFour environmental regulators (Environment Agency, Natural Resources Wales, SEPA, NIEA); PackUK is the scheme administrator that sets fees
Producers obligatedYesYes
RegistrationRequired, Producer joins a PRO; the PRO registers with the MPCARequired, Report packaging data (RPD) service, run by Defra and the regulators
Producer organisationone producer responsibility organisation: Circular Action Alliance; membership requiredproducer compliance schemes; membership optional
Transfer of responsibilitynot yet publishedNot allowed
Revenue counted asnot yet publishedworldwide revenue, GBP, previous accounting year
Who counts as the producerprimary: manufacturer, brand licensee, brand owner, importerother: manufacturer, importer, online marketplace; primary: brand owner, packer and shipper, importer, online marketplace, seller; secondary: brand owner, packer and shipper, importer, online marketplace, seller; service: brand owner, packer and shipper, manufacturer, importer, seller; shipping: brand owner, packer and shipper, importer, online marketplace, seller; tertiary: brand owner, packer and shipper, importer, online marketplace, seller

The two programmes are organised differently. Minnesota uses one producer responsibility organisation; United Kingdom uses producer compliance schemes. 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 United Kingdom cover, side by side

Each row below is one published feature of the two programmes; a cell reads “not yet published” when Minnesota or United Kingdom has no verified entry for it in the dataset.

Scope, producer duties, categories, labelling and targets, Minnesota and United Kingdom
AspectMinnesotaUnited Kingdom
Materials coveredpackaging, paper productsaluminium, fibre based composite, glass, paper and card, plastic, steel, wood, other
Product classes coveredpackaging, paperprimary packaging, secondary packaging, shipment packaging, tertiary packaging, reusable packaging
Excluded from scopeexempt materialscharities supplying or importing packaging
Sales channels addressedphysical retail, remote sale, other distributionretail, wholesale, online, online marketplace
Producer duty: primary packagingmanufacturer; licensee; brand_owner; importerbrand_owner; packer_shipper; importer; marketplace; seller
Exemption 1A de minimis producer introduced under one ton or earned under $2,000,000 in global gross revenue in its most recent fiscal year.Charities that supply or import filled or unfilled packaging in the UK, excluding subsidiaries that trade for profit.
Producer duty: secondary packagingnot yet publishedbrand_owner; packer_shipper; importer; marketplace; seller
Producer duty: tertiary packagingnot yet publishedbrand_owner; packer_shipper; importer; marketplace; seller
Producer duty: shipping packagingnot yet publishedbrand_owner; packer_shipper; importer; marketplace; seller
Producer duty: service packagingnot yet publishedbrand_owner; packer_shipper; manufacturer; importer; seller
Producer duty: other packagingnot yet publishedmanufacturer; importer; marketplace
Reporting categoriesnot yet published8, material and packaging class
Published targetsnot yet publishedplastic_recycling_obligation 57 by 2026-12-31; plastic_recycling_obligation 59 by 2027-12-31; glass_recycling_obligation 76 by 2026-12-31; glass_recycling_obligation 78 by 2027-12-31; aluminium_recycling_obligation 62 by 2026-12-31; aluminium_recycling_obligation 63 by 2027-12-31; steel_recycling_obligation 81 by 2026-12-31; steel_recycling_obligation 82 by 2027-12-31; wood_recycling_obligation 46 by 2026-12-31; wood_recycling_obligation 47 by 2027-12-31; paper_board_fibre_composite_recycling_obligation 77 by 2026-12-31; paper_board_fibre_composite_recycling_obligation 79 by 2027-12-31

Thresholds and exemptions in Minnesota and United Kingdom

Every verified threshold Minnesota and United Kingdom publish, as each states it.

Verified thresholds in Minnesota and United Kingdom
PlaceMeasureAmountEffectBasis as published
Minnesotapackaging tonnage1 short tonexempt belowcovered material introduced, most recent fiscal year
Minnesotarevenue$2,000,000exempt belowglobal gross revenue, most recent fiscal year
United Kingdompackaging tonnage25 tonnesregistration triggerpackaging supplied or imported in the UK in the previous calendar year
United Kingdomrevenue£1,000,000registration triggerworldwide annual turnover
United Kingdompackaging tonnage50 tonnesreduced dutywith turnover above 1 million and up to 2 million pounds, an obligated producer is small; above 50 tonnes with turnover over 2 million pounds is large

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.

United Kingdom exemption: Charities that supply or import filled or unfilled packaging in the UK, excluding subsidiaries that trade for profit. 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

United Kingdom publishes per-kilogram rates in the dataset; Minnesota does not. The rows therefore show United Kingdom only. Until both sides publish per-kilogram rates for the same material class, a fee comparison between Minnesota and United Kingdom would mean inventing a figure, and this page does not do that.

United Kingdom: the 2025-26 fee schedule of PackUK extended producer responsibility for packaging (base fees), effective June 27, 2025, is the source of the per-kilogram rates used on this page.

United Kingdom 2025-26: the category “Paper and card” is published at 196 GBP/tonne.

United Kingdom 2025-26: the category “Plastic” is published at 423 GBP/tonne.

United Kingdom 2025-26: the category “Glass” is published at 192 GBP/tonne.

Deadlines in Minnesota and United Kingdom

Each verified date, with the period it covers when one is given.

Verified deadlines in Minnesota and United Kingdom
PlaceKindDateCovers
MinnesotaregistrationJuly 1, 2026not yet published
MinnesotareportMay 31, 2026not yet published
MinnesotaotherDecember 31, 2026not yet published
MinnesotaotherOctober 1, 2028not yet published
MinnesotapaymentFebruary 1, 2029not yet published
MinnesotapaymentFebruary 1, 2030not yet published
MinnesotapaymentFebruary 1, 2031not yet published
United KingdomreportOctober 1, 2026the first half of 2026
United KingdomreportApril 1, 2027the second half of 2026
United KingdomreportApril 1, 20272026-P0
United KingdomregistrationOctober 1, 2026not yet published
United KingdomregistrationApril 1, 2027not yet published
United KingdomotherJanuary 31, 2027calendar year 2026

The earliest annual report date is May 31 in Minnesota and April 1 in United Kingdom, 60 days apart. United Kingdom leaves less time to prepare, so its data has to be ready first.

Penalties in Minnesota and United Kingdom

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 United Kingdom

How the report file for Minnesota compares with the one for United Kingdom.

Report file layouts for Minnesota and United Kingdom
AspectMinnesotaUnited Kingdom
LayoutMinnesota interim producer supply report by material class 2026-09-29 (interim, built from CAA guidance)UK EPR packaging data file (large and small producer) 2026 specification, GOV.UK page last updated 19 August 2026
RecipientCircular Action Alliance (Minnesota PRO)The four UK environmental regulators through the Report packaging data (RPD) service
How it is submittedCAA producer portal. The customer signs in and submits.Report packaging data service on GOV.UK. The customer, as an approved person, uploads the CSV. A compliance scheme can do this on the producer's behalf.
File typecsvcsv
Encodingutf-8utf-8
Delimiter,,
Decimal separator.
Columns415
Required columns4 of 46 of 15
Weight unitlbkg
Period basiscalendar yearhalf year

United Kingdom report specification: GOV.UK Report packaging data: create your reporting file, Table 1a (large producers) and Table 1b (small producers), with code tables 2 to 7

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 United Kingdom

Plan around the earlier report date first. United Kingdom asks for its first annual report on April 1, before Minnesota, so its data has to be ready first.

Questions about comparing these two programmes

Is Minnesota or United Kingdom stricter on packaging EPR?

Both require producers to register. United Kingdom asks for its first annual report earlier, on April 1 against May 31 in Minnesota.

Do I register in both Minnesota and United Kingdom?

Minnesota requires producers to register. United Kingdom requires producers to register.

How do the fees per kilogram compare in Minnesota and United Kingdom?

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 United Kingdom?

The earliest annual report date is May 31 in Minnesota and April 1 in United Kingdom, 60 days apart. United Kingdom leaves less time to prepare, so its data has to be ready first.

How these figures are made

Our reviewers.

Sources

  1. 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.
  2. 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.
  3. 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.
  4. 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
  5. 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
  6. 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
  7. revisor.mn.gov: 115A.1462 retrieved
    Original wording: civil penalty not to exceed $25,000 per day of violation
  8. gov.uk (how to comply with packaging recycling obligations as a large producer) retrieved
    Original wording: go to schedule 5 of the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (as amended)
    Original wording: A compliance scheme cannot pay your waste disposal fees for you.
    Original wording: you must meet your recycling obligations, including submitting your certificate or statement of compliance, by 31 January 2027
    Original wording: Packaging recycling targets 2025 to 2027
  9. gov.uk: epr for packaging what you must do as a small producer retrieved
    Original wording: Each of the 4 nations of the United Kingdom has its own regulator. You’ll be reporting to and monitored by the regulator for your nation.
    Original wording: the fee is: £1,303 if you register directly with your environmental regulator £696 if you register through a compliance scheme
    Original wording: Compliance schemes are third parties that help organisations meet the EPR for packaging requirements.
    Original wording: annual turnover of more than £1 million and supplies more than 25 tonnes and no more than 50 tonnes of packaging
  10. gov.uk: check if you must comply with epr for packaging 2 retrieved
    Original wording: you supplied or imported more than 25 tonnes of packaging in the UK in the previous year
    Original wording: you must get your annual turnover from the last accounts that were available before 7 April 2026.
    Original wording: your annual turnover worldwide was £1 million or more
    Original wording: Charities that supply or import filled or unfilled packaging in the UK are exempt from EPR for packaging requirements.
  11. legislation.gov.uk: 1 retrieved
    Original wording: a brand owner; (ii) a packer/filler; (iii) an importer or first UK owner; (iv) a distributor; (v) an online marketplace operator;
  12. gov.uk (packaging data check reporting periods and submission deadlines) retrieved
    Original wording: 1 January to 30 June 2026 1 October 2026
    Original wording: 1 July to 31 December 2026 1 April 2027
    Original wording: 1 January to 31 December 2026 1 April 2027
    Original wording: you must register for EPR for packaging each year, and pay the applicable fees by 1 October.
    Original wording: you must register for EPR for packaging each year, and pay a registration fee by 1 April.
  13. gov.uk: report packaging data create your reporting file retrieved
    Original wording: Report the weight of the individual materials used in the packaging you have supplied. You must report each material type separately.
    Original wording: Add a new row of data for each packaging activity and each type of packaging you need to report.
  14. gov.uk (2025) retrieved
    Original wording: This document provides base fees for year 1 (2025 to 2026) of the Extended Producer Responsibility (EPR) for packaging scheme.
    Original wording: Paper and card 196
    Original wording: Plastic 423
    Original wording: Glass 192
Model both: Minnesota and United KingdomCompare another pair

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