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.
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.
| Measure | Minnesota | United Kingdom | Stricter |
|---|---|---|---|
| Registration duty | Required | Required | Same |
| Producer organisation | one producer responsibility organisation | producer compliance schemes | 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 | April 1 | United Kingdom |
| Published penalties | 1 published | not yet published | Not comparable |
| Report file | csv | csv | Not comparable |
| Paper fee, cheapest matched rate | not yet published | 196 GBP/tonne | Not comparable |
| Plastic fee, cheapest matched rate | not yet published | 423 GBP/tonne | Not 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.
| Aspect | Minnesota | United Kingdom |
|---|---|---|
| Regime | Minnesota packaging EPR law, Minnesota Statutes sections 115A.144 to 115A.1463 | Extended producer responsibility (EPR) for packaging, under the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 |
| Regulator | Minnesota Pollution Control Agency | Four environmental regulators (Environment Agency, Natural Resources Wales, SEPA, NIEA); PackUK is the scheme administrator that sets fees |
| Producers obligated | Yes | Yes |
| Registration | Required, Producer joins a PRO; the PRO registers with the MPCA | Required, Report packaging data (RPD) service, run by Defra and the regulators |
| Producer organisation | one producer responsibility organisation: Circular Action Alliance; membership required | producer compliance schemes; membership optional |
| Transfer of responsibility | not yet published | Not allowed |
| Revenue counted as | not yet published | worldwide revenue, GBP, previous accounting year |
| Who counts as the producer | primary: manufacturer, brand licensee, brand owner, importer | other: 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.
| Aspect | Minnesota | United Kingdom |
|---|---|---|
| Materials covered | packaging, paper products | aluminium, fibre based composite, glass, paper and card, plastic, steel, wood, other |
| Product classes covered | packaging, paper | primary packaging, secondary packaging, shipment packaging, tertiary packaging, reusable packaging |
| Excluded from scope | exempt materials | charities supplying or importing packaging |
| Sales channels addressed | physical retail, remote sale, other distribution | retail, wholesale, online, online marketplace |
| Producer duty: primary packaging | manufacturer; licensee; brand_owner; importer | brand_owner; packer_shipper; importer; marketplace; 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. | Charities that supply or import filled or unfilled packaging in the UK, excluding subsidiaries that trade for profit. |
| Producer duty: secondary packaging | not yet published | brand_owner; packer_shipper; importer; marketplace; seller |
| Producer duty: tertiary packaging | not yet published | brand_owner; packer_shipper; importer; marketplace; seller |
| Producer duty: shipping packaging | not yet published | brand_owner; packer_shipper; importer; marketplace; seller |
| Producer duty: service packaging | not yet published | brand_owner; packer_shipper; manufacturer; importer; seller |
| Producer duty: other packaging | not yet published | manufacturer; importer; marketplace |
| Reporting categories | not yet published | 8, material and packaging class |
| Published targets | not yet published | plastic_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.
| 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 |
| United Kingdom | packaging tonnage | 25 tonnes | registration trigger | packaging supplied or imported in the UK in the previous calendar year |
| United Kingdom | revenue | £1,000,000 | registration trigger | worldwide annual turnover |
| United Kingdom | packaging tonnage | 50 tonnes | reduced duty | with 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.
| 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 |
| United Kingdom | report | October 1, 2026 | the first half of 2026 |
| United Kingdom | report | April 1, 2027 | the second half of 2026 |
| United Kingdom | report | April 1, 2027 | 2026-P0 |
| United Kingdom | registration | October 1, 2026 | not yet published |
| United Kingdom | registration | April 1, 2027 | not yet published |
| United Kingdom | other | January 31, 2027 | calendar 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.
| Aspect | Minnesota | United Kingdom |
|---|---|---|
| Layout | Minnesota 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 |
| Recipient | Circular Action Alliance (Minnesota PRO) | The four UK environmental regulators through the Report packaging data (RPD) service |
| How it is submitted | CAA 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 type | csv | csv |
| Encoding | utf-8 | utf-8 |
| Delimiter | , | , |
| Decimal separator | . | |
| Columns | 4 | 15 |
| Required columns | 4 of 4 | 6 of 15 |
| Weight unit | lb | kg |
| Period basis | calendar year | half 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
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
- 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
- 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
- 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.
- 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;
- 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.
- 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.
- 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
The free plan is enough to start. We estimate and prepare; you sign and submit.