Minnesota packaging EPR: who must report, deadlines and fees

Program status: PRO confirmed — pre-fee phase.

Who must report

The producer is generally the brand owner of packaged products sold, offered or distributed into Minnesota. If there is no brand owner in the state, the licensee or importer may be the producer. Selling direct to consumers, including online, counts.

Small-producer exemption

• Revenue: exempt below $2,000,000 (Small-producer revenue threshold).
• Tonnage: exempt below 1 short tons of covered material into Minnesota.

Producer responsibility organization

Circular Action Alliance.

Upcoming deadlines

Supply report due 2026-05-31.

Fee basics

Not yet published

Notes

Exempt under 1 ton into Minnesota or under $2M global revenue (Minn. Stat. 115A.1441). PRO membership required since July 2025. Interim producer report (CY2025) due May 31, 2026; reimbursement floor starts 2029.

Sources

All rules, sources and changelog