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Producers

As EPR legislations are passed in different states, this is your go-to page for information about joining LPMA powered by Interchange 360.

Who Should Join?

Brand-owners, retailers, distributors of petroleum and automotive products and their associated packaging that are captured by the definition of “Producer” in state EPR laws and as such will have a compliance liability. 

Examples of products that would be included in EPR laws include motor oils, engine lubricants or additives, anti-freeze, transmission/brake/gear oils, or other automotive, mechanical, and motor liquids. Typical packaging formats include rigid plastic or HDPE, bag-in-box, pales (e.g., 5-gallon buckets), metal, multi-layer tubes or bottles, aerosols, or other container designed for single-use.

Producers are encouraged to review state-specific regulations or contact Interchange 360 for more information.

Producer Webinar

We held our first Producer Webinar on November 6, 2024, where we provided further guidance on our processes and answered questions from attendees. Producers are encouraged to watch the webinar replay to help you better understand the next steps for compliance.

Notice of Intent to Join

If you are a Producer intending to join LPMA powered by Interchange 360, please complete the Notice of Intent form below. Completing the NOI allows us to keep you informed of program development.

For Colorado, we encourage you to complete the Participation Agreement and submit it to us as soon as possible to ensure you are in compliance with Producer obligations under the Colorado Producer Responsibility Program for Statewide Recycling Act.

LPMA is also developing compliance solutions in response to new regulations in Oregon, California, Maine, Vermont and Minnesota.






    Important Documents

    Preparing for Compliance

    Data Requirements

    Preparing-for-EPR-Compliance-Data-RequirementsDownload

    EPR Information by State

    FAQs

    How often and when do we report to LPMA powered by Interchange 360 on applicable product sales into applicable states?

    Reporting and payment of environmental fees/producer responsibility dues are to be done on a quarterly basis and within one month after each quarter end.  For example, for the quarter July 1st to September 30th, these applicable sales should be reported on and paid for by October 31st.

    We sell directly to customers, but we also sell to distributors. Should we provide data only for what we ship directly, or is it expected that we also estimate what our distributors might send to applicable states?

    The goal is to ensure that all of your applicable products sold into applicable states are reported.  For sales through distributors, individual state EPR laws would define who is considered a Producer.  If your distributors are considered a Producer, are registered with a Producer Responsibility Organization and have an agreement with you that they will report on and pay any applicable environmental fees/producer responsibility dues, then sales to those distributors can be excluded from your reporting to LPMA powered by Interchange 360.

    The term “Producer” is mentioned in the LPMA powered by Interchange 360 documents. Are you referring to the “brand owner,” or are you also including private label products, for which we are not the brand owner?

    Producer is a term which will be defined in each individual state EPR laws including categorization of Brand Owners.  For example, the Colorado EPR law includes a “Producer Determination Flow Chart”.  Private label products where the brand owner is a considered a producer, where the brand owner is a member of a PRO and reporting on and paying the applicable fees/dues, should not be included in your reporting.  For additional clarity, it is recommended that you have the brand owner confirm to you that they are a member of a PRO and taking responsibility for the applicable fees/dues on the private label products.

    Will the United States have product EPR fees like Canadian provinces?

    In the United States, the fees will be set by the PROs (like LPMA powered by Interchange 360) to cover whatever the obligations are under each state regulation.  As such, there would then be a fee for each product (but in this case set by the PRO as opposed to a provincial organization (like in BC, AB etc.). And each product types and producer determination would be set by each state and we expect that there will be some variances between states