FAQs

EPR stands for Extended Producer Responsibility. For the Producer, this means that their responsibility spans from the entire lifecycle of the product, meaning that it extends through the post-consumer phase, including waste reduction, recovery, recycling, and reuse, and in many cases, includes the design, operation, and financing of the recycling program. 

The intent of state EPR laws is to shift financial responsibility to producers for the products and packaging that go into the marketplace and away from the municipalities and regional waste authorities.

Most states have many similar requirements related to EPR. The regulatory focus in each state is on brand owners (Producers) or companies that license or trademark a brand in which the product is sold or brought into the state by a third party. Producers often develop a Producer Responsibility Organization (PRO), which manages the collection, transport, and recycling of products to ensure environmentally sound management of these products.  

Typical Features:

• Producers are required to comply with the State EPR Law
• Producers can form/join a Producer Responsibility Organization (PRO) or develop an Alternative Collection Program (ACP)
• Producers fund the PRO or ACP by paying fees based on volume/amount sold by product type and by state

State EPR laws apply to Producers of many consumer-based products across multiple industries, including the petroleum and automotive industry. While there can be slight variations in applicability between states, in general state laws requires the Producer or “first-seller” of a product and its packaging in a state to comply. State EPR laws require Producers to be responsible for the products that they make and sell. Including the post-consumer collection and recycling.

To understand the particularities and differences of each state, the Product Stewardship Institute has developed a comparison tool that is accessible through its webpage.

The Consumer Product Goods (CPG) packaging collection programs, often called curbside residential collection program,  have similar objectives to Interchange 360 in that they aim to provide the material back to their members for the creation of new products and packaging. Petroleum and automotive packaging often contaminates and adds costs the CPG recycling stream and makes it cost-prohibitive to collect and recycle in a co-mingled system. Globally, where there is an EPR requirement for Packaging, Petroleum and Automotive packaging is almost always collected separately as it is more efficient, more cost-effective and provides better environmental outcomes.

Interchange 360 is a National EPR program built by industry, for industry. It is a National 501(c) nonprofit organization that is transparent and accountable to its Members and Participants in providing compliance and Circular Economy solutions. 

Working collaboratively with other industry organizations, Interchange 360 enables member compliance in all EPR states and future EPR states by providing state-specific solutions for petroleum and automotive products and packaging.

Interchange 360 members include petroleum and automotive product brand owners and Retailers. Our approach is flexible with a focus on providing solutions according to the specific state’s needs.

Note: While our legal operating name is the Lubricants Packaging Management Association (LPMA) powered by Interchange 360.,we use Interchange 360 as our outward facing name.

Interchange 360 is Producer-controlled and is governed by the Board of Directors and supported by the CEO and Management team using a compliance execution model.

As a National EPR program for the Petroleum and Automotive Industry, Interchange 360 makes compliance easy and efficient through: ​ 

• Cost efficiencies from sector-wide collaboration​ 
• Execution through an experienced team and industry knowledge ​ 
• Producer-controlled and industry-specific solutions ​ 
• Right-sized design to provide a solution according to the specific state’s needs 

No. However, if your company is eligible to join Interchange 360 you should do so as soon as possible to begin the process of complying with relevant EPR laws. Your company will be responsible for paying any fees/dues dating back to the beginning of the program planning phase for states in which it is obligated under EPR laws. 

Any company who believes they may meet the definition of Producer under a State packaging EPR law, should review the regulation carefully to determine whether it they are a covered producer. Interchange 360 is not able to provide legal advice or make this determination for you.

It depends on the products each Producer sells and potentially on the rules in each state. For products not covered by Interchange 360 that are covered by state programs, Producers either must join the state-approved Producer Responsibility Organization (PRO) or file an independent producer program plan where allowed. Certain states may also require Producers that are members of Interchange 360 to register with the PRO. If this becomes the case, Interchange 360 will alert members obligated in those states. 

Interchange 360 is the National EPR program for the Petroleum and Automotive Industry. If you sell products into a state with an EPR Law, you will be required to comply with that Law by reporting your sales and meeting the state collection and recycling targets.

Interchange 360 makes compliance easy and efficient for the industry through:

• Cost efficiencies from sector-wide collaboration 
• Execution through an experienced team and industry knowledge
• Producer-controlled and industry-specific solutions
• Right-sized design to provide a solution according to the specific state’s needs

All producers of petroleum and automotive products and their associated packaging are welcome to join Interchange 360.

While EPR laws vary from state to state, for the most part obligated Producers are required to register with the approved PRO or in some cases submit an independent program plan. If not, they could face state-imposed penalties. Registering with Interchange 360 helps companies producing applicable products comply with EPR laws. 

For Colorado – please complete the Participation Agreement on the Colorado State Response Page.

For Oregon – please complete the Participation Agreement on the Oregon State Response page.

For California – please complete the Participation Agreement on the California State Response page.

For Vermont – please complete the Participation Agreement on the Vermont State Response page.

Once you have completed these agreements, we will keep you advised of additional state programs.

Each agreement covers the requirements unique to each state law. 

Anyone authorized by the company to sign legal agreements. 

Reporting and payment of environmental fees/producer responsibility dues are to be done on a monthly basis and within one month of the end of the following month.  For example, for July 1, these applicable sales should be reported on and paid for by August 1.

Planning Fees are intended to fund the activities needed for program start-up, including development of the EPR Plan, engagement with state EPR leads, engagement with stakeholders, preparation of an operational plan, IT, communications, legal and administration. Planning Fees stop when Implementation Fees begin. ​ 

Implementation Fees are intended to fund the operation of the program including payments to service providers, infrastructure development, public communications, state oversight costs, legal, IT and administration.  

The fees are needed to cover the costs of the program start-up including development of the EPR Plan, engagement with state EPR leads, engagement with stakeholders, preparation of an operational plan, IT, communications, legal and administration. 

Producers will need to fill out and submit a Remittance Report on a quarterly basis for each state. The Remittance Form, along the comprehensive Producer Guidance Document, can be found in our Producer Resource Center.

We take data security very seriously. Interchange 360 does not disclose confidential company data, including sales or volume, with regulators, competitors, or the public. 

Below is a list of some of the important acronyms related to Interchange 360: 

• EPR – Extended Producer Responsibility
• PRO – Producer Responsibility Organization
• LPMA – Lubricants Packaging Management Association
• ACP – Alternative Collection Program
• PPA – Poison Prevention Act
• PSI – Product Stewardship Institute
• CPG – Consumer Product Goods
• NLCRC – National Lubricant Container Recycling Coalition
• CAA – Circular Action Alliance