Missouri, Rhode Island Weigh EPR Laws Targeting Packaging

Two more states, Missouri and Rhode Island, are considering extended producer responsibility (EPR) laws that create new fees for distributors and other businesses that sell packaged products.

In Missouri, H.B. 3504 would require producers of packaging and paper products to join or form a nonprofit producer responsibility organization (PRO) that would fund and manage a statewide recycling system. The PRO would be tasked with conducting recycling needs assessments, developing five-year recycling plans, and ensuring convenient and equitable recycling access for residences, businesses, schools, and public buildings. Companies designated as producers, which can include distributors, would have to pay annual dues to the PRO.

Rhode Island is considering nearly identical legislation, H.B. 7910 and S.B. 2656, that would similarly require producers of packaging and paper products to fund and manage the recycling, composting, and reuse of their products. A PRO would be set up to oversee the program, set recycling targets, and ensure compliance through annual reporting audits. Producers, including distributors, would have to join the PRO and pay fees to sell their products in the state.

FEDA, the National Association of Wholesaler-Distributors (NAW), and other business advocacy groups oppose EPR laws because they create new costs and reporting requirements for distributors that have little to no say in how the products they sell are packaged. Additionally, EPR laws delegate sweeping regulatory authority to PROs, which are private, third-party organizations that can effectively impose regulatory requirements with minimal oversight.

The legality of EPR laws remains in question. The NAW filed a lawsuit last year to block the country’s first EPR law, which was set to go into effect in Oregon. In February 2026, a federal court issued a preliminary injunction that prohibited the state from enforcing the law. The case is scheduled to go before the U.S. District Court for the District of Oregon on July 13.