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Producers

Resource Center

Welcome to the Interchange 360 Producer Resource Center, your hub for resources on regulatory compliance for Producers of petroleum and automotive products and their associated packaging. On this page, Members and Participants can access guidance on Extended Producer Responsibility (EPR) and best practices in circular materials management to fulfill compliance obligations and promote environmental stewardship.

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.

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