Compliance
Once producers register with Interchange 360 by completing the Participation Agreements for states in which they sell items on the Applicable Products List, they must report the data on their materials and pay fees to cover the cost of the program monthly.
EPR Reporting
Each month, registered producers will submit an EPR Fee Remittance Form to report sales data by state based on the Applicable Products List and calculate their total remittance owing for the reporting period. Sales data reporting and payment is due 30 days after the reporting period ends.
Please email your completed Remittance Form to accounting@interchange360.com. If you still need payment advice, our Finance Team can provide this you this by emailing the same address.
EPR Fees & Dues
Interchange 360 has established a fee/dues schedule that is intended to fund the Extended Producer Responsibility (EPR) program in each state.
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.
Reporting Guidance & Remittance Forms
FAQs
How often and when do we report to Interchange 360 on applicable product sales into applicable states?
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.
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 Interchange 360.
The term “Producer” is mentioned in the 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 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