Fee Setting
EPR Fees/Dues Overview
The foundation of Extended Producer Responsibility (EPR) programs are the fees (or dues depending on the state) producers pay to the compliance organization to manage the program and meet the producers’ obligations under the law. The costs associated with an EPR program are determined by several factors and vary from state to state, but primarily include:
- Providing recycling services and necessary infrastructure;
- Implementing required public education and outreach programs;
- Meeting reporting, auditing, and verification requirements;
- Conducting needs assessments and program plan development;
- State administration, implementation, and enforcement costs;
- Administrative costs associated with running the program; and
- Other state mandated fees.
Once the initial budget for the program is determined based upon the best available data, the compliance organization must then consider the total amount of covered materials being sold into that state and calculate the operational budget required to recycle all materials. Collection and processing costs make up a vast majority of the total budget.
State EPR laws provide strict guidelines on how producer fees can be used and require specific publicly available reporting requirements and audits for the compliance organization.
Once program costs are factored, state-mandated eco-modulation requirements must be considered. Eco-modulation is an established set of criteria that provides bonuses and/or disincentives to producers encourage more recyclable, reusuable, or compostable products. Eco-modulation must be applied while still ensuring the overall costs of the program are covered.
Fees/Dues are reviewed and recalibrated on a regular basis to reflect any changes to program costs as well as eco-modulation factors.
Fee/Due Setting Policy
In Fall 2025, Interchange 360 convened a working group of manufacturers, distributors, and retailers to develop a fee/due setting policy that ensures consistency, equity, and transparency across all jurisdictions where Interchange 360 operates. The policy ensures future fees/dues meet regulatory obligations for each state while providing fairness, cover the cost of the program, and allow producers to plan and adapt effectively.
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