Minnesota's packaging EPR law is HF 3911, the Packaging Waste and Cost Reduction Act, enacted in 2024 and administered by the Minnesota Pollution Control Agency. Producers were required to join the PRO by July 1, 2025, and to submit simplified reporting — brand information, not packaging tonnage — to the Circular Action Alliance by May 31, 2026, supporting the PRO's July 1, 2026 annual registration with the MPCA. Full supply-data reporting comes later, in the build-out toward fees that begin February 1, 2029. Minnesota runs on a later timeline than the early states: the producer responsibility organization's stewardship plan and the producer cost-share phase in over the following years, with producers expected to cover a rising share of program costs toward the end of the decade.
Minnesota is an early-registration, later-payment program: producers had to get into the system in 2025 and report in 2026, but the heavy cost-share obligations phase in later than in Oregon or Colorado. That sequencing means a producer can be registered and reporting in Minnesota while the fee structure is still being built. This guide covers what HF 3911 requires, who is obligated, and the timeline.
The law and the administrator
The Packaging Waste and Cost Reduction Act was enacted in May 2024 as Article 5 of the environment omnibus bill, HF 3911 (2024 Minn. Laws ch. 116), and is codified at Minn. Stat. §§ 115A.144 to 115A.1463. It is administered by the Minnesota Pollution Control Agency. It runs through a producer responsibility organization, with the Circular Action Alliance serving as the PRO, and follows the familiar register-report-pay structure on a Minnesota-specific schedule.
Who is an obligated producer
The producer is defined through a hierarchy that generally lands on the brand owner of the covered material, shifting to the importer or distributor where there is no in-state brand owner, with de minimis producers exempt — under one ton of covered material into the state or under $2 million in global gross revenues in the most recent fiscal year, either threshold sufficing (Minn. Stat. § 115A.1441, subds. 13, 26). Producers were required to register in 2025, so the obligated population is already identified.
The timeline
Minnesota staggers the obligations. Registration came in 2025: producers had to appoint a PRO by January 1, 2025 (Minn. Stat. § 115A.1443, subd. 1(a)), and after July 1, 2025 a producer must be a member of a registered PRO (Minn. Stat. § 115A.1448, subd. 1(a)). In 2026 the obligation was lighter than in the supply-reporting states: producers submitted brand information to the Circular Action Alliance by May 31, 2026 (stragglers filed interim producer reports by June 20, 2026), feeding the PRO's July 1, 2026 annual registration with the MPCA. Minnesota producers do not yet report packaging tonnage; supply reporting arrives with the fee build-out. The needs assessment is the MPCA's, not the PRO's: a preliminary assessment was due December 31, 2025, and the initial needs assessment is due December 31, 2026 (Minn. Stat. §§ 115A.1445, 115A.1450). The PRO's stewardship plan is due October 1, 2028 (Minn. Stat. § 115A.1451, subd. 1). Producer-funded reimbursement of service providers then phases in: at least 50 percent of net cost by February 1, 2029, 75 percent by February 1, 2030, and 90 percent by February 1, 2031 and each year thereafter (Minn. Stat. § 115A.1455, subd. 4(a)). These milestones are set in statute.
Minnesota rewards getting registered and reporting on time even before the full fee structure lands. For the multistate picture, see the US packaging EPR compliance guide; to determine obligated-producer status, see the US packaging EPR producer obligation assessment.
Primary sources
- Minnesota HF 3911 (2024), the Packaging Waste and Cost Reduction Act: Minnesota's packaging EPR law; producers registered in 2025, with the producer responsibility organization plan due later in the build-out.
- Circular Action Alliance: The producer responsibility organization designated or selected to run the program in most US packaging EPR states; producers register, report, and pay fees through it.