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July 31, 2025

All Wrapped Up: Extended Producer Responsibility for Packaging, July 2025


All Wrapped Up is a newsletter that tracks and analyzes key developments in extended producer responsibility laws for packaging. It is a subscription-based resource for King & Spalding clients who sell or distribute just about anything contained in paper and plastics packaging. We unpack statutory and regulatory developments in those states with existing laws; we explore the potential for future laws; and we cast a spotlight on hot topics in our Issue in Focus section.  

In this month’s edition of All Wrapped Up, we discuss how CAA is holding the line on its near-term deadlines in California despite a lack of regulatory authority; how the revised cost projections supporting the new SB 54 regulations were “driven almost entirely” by a lower estimate of plastic as opposed to actual cost savings for consumers; and the fact that producers are now prohibited from selling and distributing covered materials in Colorado and Oregon unless they are participating in the program. We explore the very first (and not the last!) lawsuit to challenge the constitutionality of state packaging EPR. And we take a deeper dive – in our Issue in Focus section – into how producers can assign their responsibilities to pay PRO fees and report data to their business partners.

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