EPR Fees by State: What Packaging Actually Costs in Colorado, Oregon, and California

EPR Fees by State: What Packaging Actually Costs in Colorado, Oregon, and California

Saloni Doshi
by Saloni Doshi  • updated October 14, 2026 • 6 min read

Our EPR Reporting Requirements by State resource walks through how to build your packaging data and get it into each state’s report. This post picks up with the next question: what’s it actually going to cost?

For a while, the honest answer was “it depends,” because everyone was budgeting off draft ranges. That’s changed. Colorado and Oregon have published final 2026 rates, and California has published preliminary 2027 rates ahead of its first invoices in January. Those are the three states we cover here. Minnesota, Maryland, and Washington don’t start charging fees until 2028 to 2030, and Maine doesn’t have a program yet.

Below, you’ll find a side-by-side comparison of EPR fees by state, how California’s four-part fee works, the flat fee option for smaller producers, and what all of this means for your packaging budget, today and by the end of the decade.


EPR Fees by State: A Side-by-Side Comparison

Here’s what changed in 2026: rates are finally on paper. Colorado and Oregon published final schedules, and California published preliminary 2027 rates. For the first time, you can compare states side by side instead of guessing.

What each material actually costs, by state

This table reflects dollars per pound.

  • Colorado figures are 2026 Final Dues and Oregon figures are the 2026 Final Fee Rate.

  • California figures are CAA’s preliminary 2027 rates, published October 1, 2026, and non-binding until CalRecycle approves CAA’s program plan.

  • Colorado’s and California’s rates already include passive eco-modulation. California’s plastic categories also carry additional fees, covered in the next section.

Reporting category

Colorado

Oregon

California

Kraft paper

$0.08

$0.08

$0.02

Corrugated cardboard

$0.08

$0.08

$0.03

Corrugated, tertiary and transport

$0.08

$0.00

$0.03

Paperboard

$0.08

$0.08

$0.02

Polycoated paperboard

$0.20

$0.48

$0.07

Other paper laminates

$0.30

$0.51

$0.17

Paper, small format

$0.22

$0.44

$0.04

HDPE (#2) / LDPE (#4) flexible and film

$0.48

$0.43

$0.24–0.26

HDPE / LDPE pallet wrap

$0.00

$0.34

$0.24–0.26

PP (#5) flexible and film

$0.64

$1.02

$0.27

PLA, PHA, PHB flexible and film

$0.74

$1.02

$0.24

Plastic laminates and other flexible

$0.74

$1.02

$0.24-0.25

Note: California’s plastic base rates now look cheaper than Colorado’s and Oregon’s. But every plastic category also carries a $0.03 per pound Reuse Investment Fee, a $0.26 per pound PPMF weight fee, and a $0.001 per unit PPMF component fee. That brings flexible film to roughly $0.53–0.55 per pound, plus the per-component charge.

Two things worth noticing.

1. Fiber is dramatically cheaper than flexible plastic everywhere: about five to six times in Colorado and Oregon, and even more in California.

2. Oregon charges nothing for tertiary corrugated while Colorado charges full rate. That’s the kind of state-level quirk that makes a single national packaging strategy hard.

Keep in mind these are base rates. Eco-modulation bonuses and penalties can move your final bill up or down, and in California the stakes are big. Here's how eco-modulation works in each state.


California’s Fee is Four Fees Stacked Together

California fees are built from four separate components. Rates below are from CAA’s preliminary 2027 schedule:

  1. Total Base Fee, charged per pound, varying by material category. This is the number in the table above.

  2. Reuse Investment Fee, $0.03 per pound of plastic component.

  3. Plastic Pollution Mitigation Fund weight fee, $0.26 per pound of plastic component.

  4. Plastic Pollution Mitigation Fund component fee, $0.001 per plastic component unit.

That last one is charged on the count, not the weight. If your packaging has three plastic components instead of one, you pay it three times, no matter how light they are.

Together, the three plastic-only fees add about $0.29 per pound to anything with plastic in it, plus the per-component charge. So a poly mailer’s real California rate is closer to $0.53 a pound than the $0.24 base rate in the table.

The fund those last two fees flow into is not small. SB 54 requires producers to remit $500 million a year into the California Plastic Pollution Mitigation Fund from 2027 through 2037, $5 billion in total. There’s also a separate Circular Economy Administrative Fee billed quarterly to cover CalRecycle’s enforcement costs.

How California bills: In 2027, you’ll get two invoices for your annual fees, half in January and half in July, plus a separate January invoice for the PPMF portion.


The Flat Fee Option, If You’re Small Enough

Two states let low-volume producers skip category-level calculation entirely and pay a flat amount. For a lot of mid-sized brands this turns a compliance project into a line item, and it’s underused because it isn’t well publicized.

  • Colorado - if your Colorado-allocated weight is 10 short tons or less: $800 for 1 to 2.5 tons, $1,600 for 2.5 to 5, $2,600 for 5 to 7.5, and $3,600 for 7.5 to 10.

  • Oregon - if your Oregon-allocated weight is 10 metric tons or less and your revenue is under $10 million: $1,200 for 1 to 2.5 MT, $2,500 for 2.5 to 5, $4,100 for 5 to 7.5, and $5,800 for 7.5 to 10.


EPR Fees and the Fully Loaded Cost of Packaging

EPR fees are often modest per unit today, but they’re now another line item in the fully loaded cost of your packaging. That calculation already includes unit price, freight, storage, fulfillment, operational impacts, tariffs, and risk or compliance costs.

The hypothetical scenario below shows how that plays out across a few common EcoEnclose formats.

EPR Fees: A hypothetical scenario of EcoEnclose packaging solutions.

Note: Modeled on Oregon’s 2026 final fee rates. See the table above. Oregon’s 2027 rates, published October 1, are lower for most categories because CAA is returning about $80 million in reserves to producers. Expect them to rise again in later years.

EPR fees add a new lens: the end-of-life cost of the material itself. For hard-to-recycle or multi-layer materials, fees can be big enough to change which option is truly the lowest cost once everything is counted. Other brands will find they’re already using the most cost-effective packaging, just at a slightly higher total cost than before.

Either way, EPR fees are one more reason to judge packaging on its full cost, not just its unit price.


So What Does This Actually Cost You?

EPR fees only apply to the units you sell into states with active programs. That’s the single biggest factor in what you’ll actually pay, and it’s the piece most cost estimates skip.

In 2027, Colorado, Oregon, and California will all be invoicing producers, each based on 2025 supply data. Together, those three states account for about 15% of the U.S. population. Add the four other EPR states and you’re at about 21%.

Where we are

Share of U.S. population

Poly mailer

Paper mailer

Shipping box

2027: Colorado, Oregon, and California invoicing

15%

2.2%

0.4%

0.2%

Around 2029: all seven states charging

21%

3.1%

0.7%

0.3%

If all 50 states adopted similar programs

100%

14%

4.7%

1.8%

Note: Modeled on the same three formats shown in the chart above: a 10" x 13" poly mailer (0.028 lb, $0.10 per unit), a 9.5" x 14.5" kraft paper mailer (0.11 lb, $0.13 per unit), and a 9" x 12" x 0.75" shipping box (0.23 lb, $0.75 per unit). Uses Colorado’s and Oregon’s 2026 rates and California’s preliminary 2027 rates, including California’s plastic-only fees. States without published rates use the average of those three. Percentages show EPR fees as a share of each item’s price, averaged across all U.S. sales. State shares follow CAA’s population apportionment method.

Two takeaways from that table.

1. EPR fees are real, but they don’t yet make paper the cheaper option.

Paper carries a much lower rate per pound than plastic, but it also weighs more, so the per-unit gap is smaller than the rate table suggests.

In Colorado, a poly mailer pays about 1.3¢ in EPR fees and a kraft paper mailer about 0.9¢. Even in California, the most expensive state for plastic, the poly mailer pays about 1.6¢ against 0.2¢ for kraft. That 1.4¢ difference doesn’t close the 3¢ price gap between the two.

Today, switching from poly to paper is a sustainability decision, not a cost-saving one.

2. The gap is set up to widen.

If every state adopted similar programs at today’s rates, EPR would add about 14% to the cost of a poly mailer, compared with under 5% for kraft paper and under 2% for a box. Even then, poly would still come out slightly cheaper per unit, at about 11.4¢ versus 13.6¢.

But rates aren’t standing still. California’s charge on virgin plastic is designed to rise as more brands earn bonuses, and eco-modulation increasingly rewards PCR content and recyclability.

Brands that run these numbers now get to choose when to make the switch, instead of having a fee schedule choose for them.


Know Your Numbers, Then Change Them

The rates above only turn into a real number once you know exactly what you’re putting into each state: which SKUs, which components, and how much they weigh. If you haven’t built that dataset yet, that’s step one, and it’s the same work that gets your annual reports done.

Then look past the base rate. Eco-modulation bonuses, California’s rising charge on virgin plastic, and simple design changes like dropping a component or switching materials can all move your bill. The brands that know their numbers now are the ones that get to make those calls on their own timeline, not the state’s.


EcoEnclose packaging experts

About EcoEnclose

EcoEnclose is a sustainable packaging provider helping brands optimize packaging choices to align with EPR laws—reducing fees, minimizing plastic use, and building smarter long-term strategies.