What does Minnesota's packaging EPR law require from a brand?
A brand that sells packaged goods in or into Minnesota and is not exempt had to register with CAA by July 1, 2025, and CAA reports the registered producers and their brands to the state each year. Fees come later: CAA's stewardship plan is due in October 2028, and producers must cover at least half of program costs from February 1, 2029. A small producer with under one ton of covered material in Minnesota, or under $2 million in global revenue, is exempt.
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What the law covers
The Packaging Waste and Cost Reduction Act was signed on May 21, 2024. It covers packaging, food packaging and paper products sold, offered for sale, distributed or used to ship a product within or into Minnesota, including online purchases and shipments.
The Minnesota Pollution Control Agency oversees the program. CAA is the producer responsibility organization, and the agency confirmed its registration on February 18, 2025.
Who is a producer
The definition is tiered. For a product sold in a store under the manufacturer's own brand, or with no brand, the producer is the manufacturer. Otherwise it is the licensee of the brand, and if there is none, the brand owner.
For online sales the packaging is split in two. The producer of the packaging that holds the product is found the same way as for a store sale. The producer of the packaging used to ship the order is the person that packages and ships it. If none of those apply, the producer is the person that first distributes the item in or into Minnesota. The online split is explained in am I a producer: online brands and marketplace sellers.
Who is exempt
Law firm summaries describe a small producer exemption for companies that sell or distribute less than one ton of covered material into Minnesota in a year, or that earned global revenue of less than $2 million. Exempt producers do not have to register.
Dates to know
- July 1, 2025: producers had to register with CAA
- May 31, 2026: CAA's simplified supply reports for Minnesota were due
- July 1, 2026: CAA's first annual registration deadline with the state, including its list of producers and brands
- December 31, 2026: the state's needs assessment is due
- October 1, 2028: CAA's stewardship plan is due to the state
- February 1, 2029: producers must cover at least 50 percent of program costs, and the program begins in early 2029
What this means now
No Minnesota fees are being invoiced yet. CAA collects fees after the stewardship plan is in place. What is live today is registration and an accurate list of the brands and products a producer sells into the state.
The packaging record that will set Minnesota's fees is the same record every other state uses, with a material and weight for each component. It is built once and kept current. The kits guide shows how: kits, sets and bundles in an EPR report.
Primary sources
- Minnesota Pollution Control Agency, Extended producer responsibility for packaging: the program, what is covered and who oversees it
- Minnesota Statutes section 115A.1441: the producer definition
- Circular Action Alliance, Minnesota: the timeline, registration and the 2029 start
- Circular Action Alliance, producer registration opens for Minnesota: the July 1, 2025 deadline
- Fredrikson, Minnesota enacts its EPR law: the deadlines and the exemption
- Kilpatrick Townsend, Minnesota's EPR law and the July 1, 2025 deadline: the de minimis exemption
- Holland and Knight, what to know now about state EPR laws: the 2028 plan and the February 2029 cost share
- Resource Recycling, Minnesota seeks public input: when CAA starts collecting fees
- Verdant Law, California finalizes packaging EPR regulations: the May 31, 2026 supply reports for Minnesota
- Food Industry Association, Minnesota EPR program overview: the tiered producer definition
FAQ
Is a brand paying Minnesota fees now?
No. CAA collects fees after its stewardship plan is in place. Producers must cover at least 50 percent of program costs from February 1, 2029.
Is there an exemption for small producers?
Yes. Law firm summaries describe it as selling or distributing less than one ton of covered material into Minnesota in a year, or earning less than $2 million in global revenue. The exact test is confirmed with the state or CAA.
Does Minnesota apply to a brand that only sells online to Minnesota customers?
Yes, if the brand is a producer and not exempt. The program covers online purchases and shipments. The brand owner is typically the producer of the packaging that holds the product, and the person that packs and ships the order is the producer of the shipping packaging.
Who runs the program?
The Minnesota Pollution Control Agency oversees it, and CAA is the producer responsibility organization that producers register with.
When does the program begin?
CAA says it begins in early 2029, after the stewardship plan due in October 2028.
This guide is general information, not legal advice. We work out who the producer is for every product, build the packaging record, prepare and file the report each cycle and keep it current. Check your exposure to see where you stand in Minnesota and the other states, or talk to us.