Why Consistency Matters in Fee Setting 

For producers navigating extended producer responsibility (EPR) requirements across multiple states, few issues are as important as predictability. As EPR laws expand and diverge, producers need confidence that fees are being set using a clear, consistent framework, one that reflects real program costs while allowing businesses to plan ahead. Interchange 360’s Fee Setting Policy was developed with exactly that goal in mind: consistency across jurisdictions, grounded in transparency and fairness. 

A Policy Built by the Supply Chain 

Our Fee Setting Policy is the result of a multi-month effort by Interchange 360’s Fee Setting Working Group, which brought together manufacturers, distributors, and retailers from across the supply chain. The working group was convened to provide direct producer input into how EPR fees and dues should be established in future programs, recognizing that those paying into the system should have a voice in how it is structured.  

Rather than developing the policy in isolation, Interchange 360 used the working group to test assumptions, discuss tradeoffs, and refine guiding principles. The outcome is a policy that reflects operational realities while aligning with state regulatory requirements.  

Consistency as a Core Principle 

At the heart of the Fee Setting Policy is the principle of consistency. The policy establishes that the same fee setting methodology will be applied across all states in which Interchange 360 operates, even though actual fee amounts may vary based on state-specific requirements and costs. This distinction is critical for producers: while no two EPR programs are identical, the approach used to calculate fees should be. 

By committing to a consistent methodology, Interchange 360 aims to reduce uncertainty and avoid adhoc or reactive fee structures. Producers operating in multiple jurisdictions can expect a familiar framework, making it easier to understand how fees are derived and why they may differ from state to state.  

Predictability Without Oversimplification 

Consistency does not mean ignoring local realities. The Fee Setting Policy explicitly recognizes that program costs vary based on state mandates, infrastructure availability, transportation distances, and other market conditions. Collection and recycling costs, public education requirements, compliance reporting, and state oversight all factor into total program costs. 

What the policy provides is a stable framework for evaluating those costs. It is applied uniformly, reviewed regularly, and recalibrated as conditions change. Regular reassessment ensures that fees continue to reflect the true cost of managing materials while avoiding sudden or unexpected shifts. Advance notice of fee changes is also built into the policy to help producers plan and budget with greater confidence. 

Designed for Long Term Program Success 

For producers, a consistent fee setting approach is not just an administrative benefit; it’s foundational to long-term compliance. Clear rules, applied the same way across states, support better forecasting, internal decision making, and packaging strategy. Just as importantly, consistency strengthens trust in the system itself. 

Interchange 360’s Fee Setting Policy reflects a deliberate, collaborative effort to balance regulatory compliance with operational clarity. By grounding the policy in consistency and developing it through a diverse working group, Interchange 360 has created a framework designed to support producers today and in the future. 

This post is the first in a series focused on each of the four principles that make up our Fee Setting Policy. Also, look for future opportunities to participate in working groups and webinars on this and similar topics.