EPR programs should prioritize environmental outcomes, such as reducing waste, increasing recycling rates, and minimizing environmental harm caused by problem materials. The programs should focus on achieving measurable targets for collection and recycling rates to reduce the environmental impact of products.

EPR systems should be managed equally by all manufacturing stakeholders, including applicable retailers, through a single, producer-led Producer Responsibility Organization (PRO). The PRO should work with regulators to establish a robust management plan, target collection goals, and recyclable products list and should be responsible for establishing a collection network, procuring recycling services, and reporting obligations. A formal process should be established in which an advisory council can submit feedback on the PRO management plan. Responsibilities should apply equally to all business models, including online commerce and marketplace facilitators. New EPR schemes should not interrupt or discourage existing recycling programs.

EPR programs should be designed to be efficient and cost-effective, with a focus on minimizing costs for producers and consumers while achieving environmental outcomes. Prior to the implementation of an EPR program, a needs assessment should be completed to define the total system costs, including the investments and activities necessary to achieve the stated legislative goals. The needs assessment should be completed by a neutral entity and reviewed by all stakeholders prior to any proposal being considered. The program should aim to find an optimal balance between material collection for recycling and cost. EPR systems should be managed by producers, not governments.

Costs of EPR programs should be shared among all manufacturing stakeholders including packaging producers, state governments, and municipalities so that the costs are not borne disproportionately by any one group. Costs should be allocated fairly and transparently, so that all manufacturing stakeholders contribute to the success of the program. If a program is funded fully by producers then producers should have proportional control. Producer responsibility should align with the entity’s level of control over product design. Policies should not interfere with the ability of a producer or supply chain entity to contractually assume their obligations under the PRO. EPR proposals should not mandate a fee assessed at the point of sale.

EPR programs should rely on an ecomodulated cost model that is structured to incentivize sustainable packaging design, reduces packaging waste, utilizes eco-friendly materials and production processes, and ensures responsible disposal and recycling of packaging waste. Consistent criteria for ecomodulation should be developed and implemented across markets and jurisdictions wherever possible. An ecomodulation system should be based on an agreed set of criteria, e.g., common definitions of recyclability. Material bans should be avoided, instead relying on ecomodulation and market forces to drive more sustainable choices, wherever commercially viable.

EPR programs should be designed to be financially sustainable over the long-term, even as market conditions change. The program should make strategic investment decisions and regularly review its financial health to ensure sustainability. Additionally, any revenue generated by the EPR system should be reinvested into the system to improve recycling infrastructure and system performance. No funding should be diverted to non-germane, general state funds.

EPR programs should be designed to be convenient and easy for consumers to participate in. As such, existing infrastructure should be used to make recycling accessible and cost effective. Retail outlets should not be subject to mandates requiring participation as collection centers. Retailers who voluntarily enter into contracts with producers to serve as collection centers may be allowed to participate.

The PRO should prioritize educating consumers and raising awareness about the benefits of recycling and the role consumers play in achieving a circular economy. This includes recycling education and awareness campaigns, improving access to recycling facilities, and encouraging consumers to make informed choices by selecting products with recyclable materials.

EPR programs should be designed to be socially inclusive and fair.