Product Stewardship Updates

January 20, 2026

A NOTE FROM OUR CEO: 
WELCOME 2026 — EPR IS ROLLING ALONG 

Happy New Year! We want to thank you for being part of PSI’s work in 2025. Your collaboration and support helped make significant progress on extended producer responsibility (EPR) possible last year—and we’re carrying that energy straight into the new year. 

 

As we step into 2026, I want to reflect on the fact that EPR has become the single biggest materials management approach in the U.S. and globally. There are now 146 EPR laws passed on 22 products (industry sectors) in 34 states. This paradigm shift did not happen overnight. Over the past 25 years, this new policy has gradually taken hold—industry sector by industry sector—starting with paint, electronics, batteries, and mattresses, and continuing on to packaging.  

 

We are now seeing real benefits from EPR laws, which have saved governments and taxpayers hundreds of millions of dollars; reduced waste through reuse and recycling; increased consumer access to material collection sites; and created thousands of jobs. There is no doubt that this policy has taken hold and will continue to be applied to more consumer products in more states. 


2026 is shaping up to be another momentous year for EPR. Legislatures in numerous states are entering the year with new and carry-over EPR legislation already filed, especially on hot products like batteries and packaging, as well as paint, mattresses, solar panels, and household hazardous waste. At the same time, multiple states are shifting focus from policy development to implementation as they transform policy concepts on paper into programs in practice. 


With your support, PSI will continue doing what we do best: bringing key stakeholders together to develop policy solutions to materials management challenges; helping stakeholders achieve greater policy consistency across states; and supporting implementation of new EPR programs. In the year ahead, we’ll deliver timely policy intelligence, convene focused problem-solving and policy development dialogues, support implementation challenges as they arise, and equip policymakers, producers, and communities with practical tools, guidance, training, facilitation, and mediation to develop and improve EPR policies and programs.  



Thank you for being part of this mission. The progress behind us—and the solutions ahead—are only possible because of this community. We’re grateful to start 2026 with you and excited for what we’ll build together.  


— Scott Cassel, CEO & Founder, Product Stewardship Institute

 


OREGON DEQ CONDITIONALLY APPROVES PRO FOR 2026 E-CYCLES PROGRAM 

On December 30, 2025, the Oregon Department of Environmental Quality (DEQ) conditionally approved Electronic Manufacturers Recycling Management Co. (MRM) as the sole Producer Responsibility Organization (PRO) for the 2026 Oregon E-Cycles program, after reviewing final revised plans submitted by MRM and Dynamic Lifecycle Innovations on December 10, 2025. DEQ rejected Dynamic’s plan, meaning no coordinating body will be designated for the 2026 program year and all program requirements will be the responsibility of MRM, which has served as a PRO since Oregon’s original electronics stewardship law was enacted. 

 

The E-Cycles program operates on an annual planning cycle, with plans for the 2027 program year due July 1, 2026. Oregon’s 15-year-old E-Cycles program was updated by legislation enacted in 2023, informed by stakeholder meetings facilitated by PSI in 2022–2023 that helped shape legislative changes and laid the groundwork for the current PRO structure. 

 


COLORADO MOVES ON TO IMPLEMENTATION PHASE WITH FINAL EPR PROGRAM PLAN APPROVAL 

Colorado is officially active in the EPR landscape! The state’s Extended Producer Colorado reached a major milestone in packaging EPR implementation this month when the Executive Director of the Colorado Department of Public Health & Environment officially approved Circular Action Alliance’s Amended Program Plan, designating it as the Final Program Plan under HB22-1355, the Producer Responsibility Program for Statewide Recycling Act. With this approval, Circular Action Alliance is required to begin implementation within six months—no later than June 9, 2026. 


The Final Program Plan details how producers will fund and operate a statewide recycling system designed to expand access, improve equity, and strengthen recycling infrastructure. Approval marks the shift from planning to implementation, including contracting, system development, education and outreach, and other readiness activities ahead of program launch. 


PSI has been closely involved in Colorado’s process from the outset, supporting advisory board facilitation and providing best-practice guidance to help producers, recyclers, local governments, and communities navigate complex program design decisions. We will continue to track implementation milestones and share updates as Colorado moves into this next phase. 

 


EU ADOPTS NEW CIRCULAR ECONOMY RULES FOR END-OF-LIFE VEHICLES 

(Aziz Er / Pexels)

The European Union reached an agreement on a new regulation to strengthen circular economy requirements for vehicles, covering their full life cycle from design to end-of-life. The regulation was approved by the European Parliament and all 27 EU Member States. A key provision requires new vehicles to be designed to support reuse, remanufacturing, and recycling of parts and materials. The regulation also introduces mandatory recycled-content targets for plastics used in new vehicles, phased in over ten years: 15 percent recycled plastic within six years and 25 percent within ten years. At least 20 percent of this recycled plastic must come from closed-loop recycling using material recovered from end-of-life vehicles. 



The agreement also allows for future recycled-content targets for other materials, including steel, aluminum, magnesium, and critical raw materials, pending the results of a feasibility study to be completed within one year of the regulation’s entry into force. 

 


NEW YORK PASSES BILL TO STRENGTHEN RECHARGEABLE BATTERY RECYCLING PROGRAM 

On December 19, 2025, Governor Kathy Hochul signed SB 73 (A) into law, strengthening New York’s rechargeable battery stewardship program by expanding the definition of “rechargeable battery” to include batteries used as the primary power source for electric scooters and electric-assist bicycles, including certain “medium-format” batteries weighing 25–50 pounds that were previously excluded.  


The amendment updates New York’s EPR program to battery address safety risks associated with lithium- ion batteries, which have caused tragic fires resulting in significant property damage, injury, and deaths. The law expands collection opportunities by requiring retailers to take-back for recycling batteries similar to the ones they sell, and gives New York City (and any city with 1 million+ residents)  enforcement authority concurrent with New York State Department of Environmental Conservation (NYSDEC) for specified provisions.  


The law also directs NYSDEC—working with the Office of Fire Prevention and Control and the New York City Fire Department—to develop safe storage and handling regulations to help reduce the fire risks associated with lithium-ion batteries, a growing concern for waste and recycling operations. PSI provided technical support and submitted testimony in support of the effort to expand New York’s rechargeable EPR battery law, alongside member NYC Department of Sanitation (DSNY) and the New York Product Stewardship Council (NYPSC).  

 

EVENTS

(kasto / Canva Teams)

B.C. EPR Regulatory Update Webinars: Newly Obligated Product Categories 


January–February 2026 | Virtual (Pacific Time) 

British Columbia has amended its Recycling Regulation to expand EPR to additional product categories, with phased program implementation beginning in 2027. These webinars will outline what’s changing, who is impacted, and how producers can meet new regulatory requirements. Newly regulated products include automotive products, battery-containing products (including vapes), canisters (such as aerosols and propane tanks up to 100 pounds), electronic signs and decorations, large 12-volt consumer batteries, and household medical sharps. 

Webinar options: 

PSI IN THE NEWS

WHAT WE'RE READING

(StudioThreeDots / Canva Teams)

  • Zero Waste Europe examines EPR for food products. A new study from Zero Waste Europe evaluates whether EPR could apply to food waste prevention and management. The report outlines potential pathways, challenges, and policy implications, offering insight into how EPR principles might extend beyond packaging and durable goods. Read more 
  • US and EU explore shared lessons on packaging policy. Industry groups note that both regions can benefit from understanding each other’s approaches to packaging regulation, particularly as more U.S. states adopt producer responsibility laws. The conversation highlights growing alignment on recyclability, design standards, and accountability frameworks. Read more 
  • Industry groups call for clarity on PPE waste under textile EPR. European stakeholders are urging policymakers to clearly define how personal protective equipment and medical devices are treated under textile EPR rules, warning that unclear classifications could create safety and compliance risks if contaminated PPE enters textile recycling systems. Read more 
  • Vape waste continues to strain recycling systems and facility safety. New analysis highlights the growing fire risks and financial impacts tied to lithium-ion batteries in disposable vapes, reinforcing calls for stronger producer responsibility and safer product design. Read more 
  • EPR frameworks may help strengthen composting infrastructure. A recent report explores how EPR reimbursement models could support composting systems and improve recovery of compostable packaging, particularly as organics infrastructure continues to develop. Read more 


The Product Stewardship Institute is a policy expert and consulting nonprofit that pioneered product stewardship in the United States. Since 2000, PSI has helped enact 146 extended producer responsibility (EPR) laws across 21 product categories in 34 states and D.C. — the bedrock on which the circular economy is built. We work with businesses, nonprofits, academia, and governments to ensure that products are responsibly managed from design to end of life. Join us at www.productstewardship.us. 

The Product Stewardship Institute, Inc. is an equal opportunity employer and provider. Persons with disabilities who require alternatively formatted materials to ensure effective communication should contact Amanda Nicholson at info@productstewardship.us or 617.236.4855.

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