6 Steps Manufacturers Should Take Before the Next Wave of EPR Regulations

Jen Levisen
Aug 6
4 min read

Takeaways from our Conversations With Friends discussion with Marty Grohman on how manufacturers can prepare for the next wave of EPR regulations.

A few years ago, most manufacturers could afford to keep one eye on Extended Producer Responsibility (EPR) and wait to see what happened.

That's getting harder to do.

As more states adopt EPR legislation, manufacturers are being asked to make decisions that reach well beyond compliance. Reporting, product development, operations, procurement, finance, end of life packaging management, packaging reduction planning, and advanced customer expectations are becoming part of the same conversation.

During a recent Conversations With Friends: The Founders' Table, SMS Collaborative Founder Annie Bevan sat down with Marty Grohman to discuss where EPR is headed and what manufacturers should be doing now to prepare.

Marty has spent his career looking for the intersection between sustainability, legislation and business, and that perspective shaped the entire conversation.

“I've always been one of these people... looking for where sustainability and economics overlap.”

One theme surfaced again and again.

Manufacturers need to prepare on two fronts.

Internally, they need the people, systems, and processes to respond as regulations evolve.

Externally, they need to understand the changing regulatory landscape, strengthen partnerships, and build credibility with customers and regulators alike.

Here are six places to start.

Internal Readiness

1. Make EPR a business conversation.

One of Marty's biggest points was that EPR has outgrown the sustainability department.

Packaging decisions affect operations. Reporting affects finance (with financial penalties looming). Product/packaging design affects engineering. Compliance affects legal. Customer expectations affect sales and marketing.

The more perspectives brought into the conversation early, the easier it becomes to respond as regulations evolve.

A simple question can reveal a lot:

Who owns EPR today?

If the answer is one person or one department, it may be time to broaden the conversation.

2. Rethink packaging before regulations force you to.

EPR isn't just changing reporting requirements. It's changing how manufacturers think about packaging from the beginning of the product development process.

As Marty put it: “Now is really the time to push and see if you can reduce the amount of packaging.”

That doesn't necessarily mean eliminating packaging. It means asking better questions.

Can unnecessary materials be removed? Can plastic be reduced without compromising product protection? Can packaging be redesigned to improve recyclability while still meeting customer expectations?

The goal isn't simply to comply with future regulations. It's to build better products.

3. Build stronger data and reporting systems.

Most EPR programs depend on information many manufacturers haven't traditionally managed in one place.

Packaging specifications. Material composition. Product volumes. Sales by state.

If gathering that information feels harder than it should, that's valuable insight.

Building stronger internal systems now won't just make reporting easier. It will also give teams better visibility into their products, packaging, and operations as new regulations emerge.

External Readiness

4. Understand your regulatory exposure.

When Annie asked why EPR suddenly feels so urgent, Marty didn't hesitate.

“I have one word for you: California.”

California's reporting requirements have become a wake-up call for many manufacturers. But they're unlikely to be the last with 6+ other states (and a few other in the wings) publishing EPR laws similarly.

Understanding where your products are sold, which states already have EPR requirements, and where legislation is moving next allows your organization to plan proactively instead of responding at the last minute.

5. Engage with the right partners early.

One of Marty's most practical recommendations was also one of his simplest.

“Go to Circular Action Alliance and register if you haven't already.”

Producer Responsibility Organizations (PROs), industry associations, and trusted advisors can help manufacturers understand changing requirements long before reporting deadlines arrive.

The organizations that engage early have more time to ask questions, understand expectations, and make informed decisions instead of scrambling to catch up.

6. Back sustainability claims with evidence.

Another theme throughout the discussion was credibility.

As expectations around sustainability continue to evolve, it's no longer enough to simply say a product is recyclable or contains recycled content.

Manufacturers increasingly need reliable data and credible verification to support those claims.

That shift isn't just being driven by customers. Regulators are asking more questions, too.

Building confidence in your sustainability data today will put your organization in a much stronger position tomorrow.

Looking Ahead

“There's a lot of economic opportunity in getting recycling and end of life right.”

That may be the biggest takeaway from the entire discussion.

EPR isn't simply another regulation to comply with. It's an opportunity to rethink products, packaging, operations, and the systems that support them.

Marty challenged manufacturers to ask a different question.

“How can we be the ones that lead—the first ones to figure it out... and achieve opportunity that way?”

That's the mindset shift.

The manufacturers that treat EPR as another compliance exercise will always be responding to the next deadline. The ones that use it to strengthen their business will be ready for whatever comes next.

Watch the Full Conversation

Missed the live session—or want to revisit it? Watch the full webinar recording.

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