Registration
Producers of petroleum and automotive products seeking to comply with state Household Hazardous Waste (HHW) and/or packaging Extended Producer Responsibility (EPR) laws should register as soon as possible with LPMA powered by Interchange 360.
Who Should Register
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 should register with LPMA powered by Interchange 360.
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.
How to Register
Producers register with LPMA powered by Interchange 360 by completing and submitting Participation Agreements for each regulated state in which they sell products. A registration confirmation email will be sent within five days of submitting a Participation Agreement.
Post-Registration Compliance
Once the Participation Agreements are signed, covered producers will pay planning and/or implementation fees to Interchange 360 based on the volume of covered material sold in each state. The fees will cover the planning and implementation of each state program. For more information on fees and reporting, visit the Producer Compliance page.
Who is the Obligated Reporting Party?
If you’re unclear about your reporting obligations, we’ve created a flowchart to help determine who in their supply chain is best suited to report data and remit fees to LPMA powered by Interchange 360:
State-by-State Producer Definitions
This document contains the general definition for producer under each state law along with the source. In most cases, the obligated producer will be the brand owner. However, please note that each producer’s situation is unique and there may be other elements of each law that determine where a producer falls within the hierarchy of obligation. In addition, several states are still going through rulemaking which could alter the definitions provided below. Producers should consult their own legal counsels before determining their obligations under EPR laws.
Note: The above information should be used for informational purposes only and not construed as legal advice. Individual Producers are encouraged to consult with their own legal counsel regarding their specific compliance obligations.