Why EPR Compliance Can’t Wait—Even Amid Industry Uncertainty

Please note: While we strive to reflect the most current information and definitions as they are communicated, EPR laws and regulations are evolving. This document is for informational purposes only and does not constitute legal advice. Businesses should consult with legal and regulatory experts for guidance specific to their situation, as requirements and interpretations of EPR laws may change over time.

EPR Is Not New—But It’s About to Reshape the Auto Aftermarket

The U.S. automotive aftermarket is navigating a period of rapid change—from shifting trade policies to supply chain disruptions and increasing operational costs. But while companies focus on immediate challenges, another critical regulatory shift is moving forward: Extended Producer Responsibility (EPR) laws for packaging.

EPR Is Not New—But Packaging EPR Changes Everything

EPR programs have existed in the U.S. for years, covering products like tires, electronics, oil, and batteries. But packaging EPR is different—it’s the first regulation that will impact nearly every brand selling automotive aftermarket parts, tools, and related products.

While some brands have had to comply with EPR before, packaging laws bring new reporting requirements, fees, and compliance obligations for companies that may have never faced these regulations before.

EPR in the U.S. vs. Europe—What’s Different?

While the U.S. is just rolling out packaging EPR, these laws are well established in Europe. However, they are not uniform across countries—each European country has its own compliance system, fees, and reporting requirements.

The same challenge is now playing out in the U.S., where EPR varies state by state, creating a complex compliance landscape for companies that sell nationwide.

What Does This Mean for the Auto Aftermarket?

Unlike past EPR laws that applied only to specific products, packaging EPR affects a much broader range of businesses. If you:

• Manufacture or remanufacture auto parts or tools under your own brand

• Import aftermarket products for resale in the U.S. (If no brand exists in the U.S., the importer is considered the responsible producer under EPR laws).

• Sell private-label products in retail, wholesale, or e-commerce

You may now be responsible for compliance—even if you’ve never had to register for an EPR program before.

And with different rules in different states, compliance is anything but simple.

• Colorado: Mandatory registration deadline for producers by October 1, 2024 (Yes - last year, but it's not too late)

• Oregon: First EPR packaging report due by March 31, 2025

• Colorado: First EPR packaging report due August 2025

• California: Packaging producer registration deadline is April 2025

• More states: Actively considering EPR legislation, meaning compliance complexity will only grow

Key Terms to Know Before the Webinar

Extended Producer Responsibility (EPR)

A policy framework that requires businesses to take financial and/or operational responsibility for the full lifecycle of their products and packaging, including waste management and recycling.

Producer Responsibility Organization (PRO)

A third-party organization that manages compliance on behalf of producers, ensuring that reporting, fees, and collection programs meet state requirements. In many states, businesses must either register with a PRO or handle compliance themselves.

Circular Action Alliance (CAA)

A nonprofit PRO designated to manage EPR compliance for packaging in states like Colorado. Companies that meet EPR thresholds must register with CAA to remain compliant.

B2B vs. B2C (Business-to-Business vs. Business-to-Consumer)

• B2B transactions (e.g., selling parts directly to repair shops) may have different compliance requirements than B2C transactions (selling to consumers through retailers).

• Colorado has not distinguished between B2B and B2C, so businesses should be prepared to report all transactions. Some states currently focus on B2C, but B2B will be phased in over time—so even if you’re B2B now, EPR could still affect you later.

Join the Auto Care Association’s Webinar to Get the Answers

EPR compliance isn’t just a policy change—it’s a business shift that will impact packaging, costs, and reporting requirements across the industry. To help companies navigate this transition, the Auto Care Association is hosting a live webinar with leading industry experts.

Webinar Details:

📅 When: Thursday, Feb. 6, 2025 | 2 - 3 p.m. ET
📍 Where: Online – Register Now

What You’ll Learn:

• The impact of EPR laws on product and packaging lifecycles

• How to manage compliance across multiple jurisdictions

• Industry strategies to simplify EPR requirements and reduce costs

• Actionable steps to prepare for March 2025’s first major reporting deadline

Featured Speakers:

• Scott Cassel, CEO, Product Stewardship Institute (PSI)

• Kirsten Zaremba, Co-Managing Director, PARTSLIFE US

• Lisa M. Tanzi, SVP & General Counsel, The Parts Authority

Don’t let compliance be another disruption. Get ahead of the regulations now and ensure your business is prepared.

Register Here

Final Thoughts: Compliance as a Competitive Advantage

EPR compliance isn’t just about avoiding penalties—it’s also an opportunity to streamline operations, improve sustainability, and strengthen industry partnerships. Companies that adapt now will be in a stronger position as regulations expand.

The first step? Understanding what’s required and how to implement compliance efficiently.

Join the Auto Care Association’s webinar and get the insights you need to take action today.