Also published as: The 10x EPR Fee Gap: What Oregon and Colorado Data Reveals About Plastic vs. Paper Costs
By Paper Tube Co. | Extended Producer Responsibility | Packaging Compliance | Sustainability
If you manage packaging for a consumer brand, you have probably heard about Extended Producer Responsibility — EPR — laws. But you may not yet know what they actually cost, or how dramatically those costs differ depending on whether your packaging is paper or plastic.
Here is the short answer: in states with published EPR fee schedules, plastic packaging can cost up to 10 times more in producer fees than paper packaging of equivalent weight. This is not a rounding error. It is a structural cost gap built into the law — and it is only going to widen as more states adopt EPR legislation.
This post breaks down the real numbers from Oregon and Colorado, explains why the fee gap exists, and shows you how to calculate your own EPR exposure — before your finance team does it for you.
What Is Extended Producer Responsibility (EPR)?
Extended Producer Responsibility is a policy framework that requires the companies that put packaging into the marketplace to fund its end-of-life management — collection, sorting, and recycling or composting. Instead of municipalities bearing the full cost of waste infrastructure, EPR shifts that financial burden to the brands whose packaging creates the waste stream.
In the United States, EPR for packaging is no longer a theoretical future. Oregon passed the Plastic Pollution and Recycling Modernization Act in 2021. Colorado passed its Packaging EPR law in 2022. California, Maine, Minnesota, and several other states have followed with their own frameworks. More are coming.
Under these laws, brands selling products into covered states must register as producers, report their packaging volumes by material type, and pay fees into a Producer Responsibility Organization (PRO) that funds recycling infrastructure. The fees are assessed per ton of packaging placed on the market, and the rate varies significantly by material.
The EPR Fee Gap: Paper vs. Plastic by the Numbers
The core insight is this: EPR fee schedules are not material-neutral. They are deliberately designed to reflect the real-world recyclability and environmental burden of each packaging type. Materials that are harder to recycle, more likely to contaminate the waste stream, or more likely to end up in landfills or oceans carry higher fees. Paper — particularly FSC-certified, paper packaging — sits at the most favorable end of the spectrum. Many forms of plastic sit at the opposite end.
Oregon EPR Fee Schedule: Paper vs. Plastic
Oregon’s Plastic Pollution and Recycling Modernization Act establishes fee rates that vary by material category. Based on published Oregon DEQ guidance and the PRO fee modeling that has been made available to producers, the differential between paper-based and plastic packaging is substantial.
| Material Type | Relative Fee Rate | Recyclability Rating | Estimated Fee Band |
| Paperboard / Paper Tubes | Low | High | $15–$40 per ton |
| Corrugated Cardboard | Low | High | $10–$30 per ton |
| PET Plastic (Type 1) | Medium | Medium | $80–$140 per ton |
| HDPE Plastic (Type 2) | Medium | Medium | $80–$130 per ton |
| Polypropylene (Type 5) | High | Low–Medium | $150–$220 per ton |
| Polystyrene (Type 6) | Very High | Very Low | $200–$350 per ton |
| Multi-layer / Mixed Plastic | Very High | Very Low | $250–$400+ per ton |
Note: Fee ranges are illustrative based on Oregon DEQ published EPR modeling and industry analysis. Final fee schedules are subject to annual PRO determination. Consult your compliance team for current rates.
Colorado EPR Fee Framework: A Similar Story
Colorado’s Packaging EPR law, administered through the Colorado Department of Public Health and Environment (CDPHE), uses a similar structure. The fee schedule — still being finalized through 2024-2025 rulemaking — follows the same principle: recyclability drives cost.
Colorado’s framework places particular emphasis on whether packaging material has established end markets, whether it is accepted in curbside programs in at least 60% of the state’s population, and whether the material is compatible with existing MRF (materials recovery facility) infrastructure. Paper packaging — including paper tubes — scores well on all three. Most plastics, particularly flexible films, polystyrene, and multi-layer structures, do not.
Preliminary Colorado modeling suggests fee differentials between paper and the least-recyclable plastics in the range of 8x to 12x per ton. For brands with significant packaging volumes, this is a six-figure swing in annual compliance costs.
Why Does the EPR Fee Gap Exist? The Environmental Economics Explained
EPR fee structures are not punitive by design — they are actuarial. They are attempting to price in the true cost of managing each material at the end of life. When you understand why paper and plastic have fundamentally different end-of-life profiles, the fee gap makes complete sense.
Paper Packaging: A Naturally Favorable Profile
• Widely accepted in curbside recycling programs across all U.S. markets
• Established, liquid commodity markets for recovered paper fiber
• Biodegrades naturally — paper tubes can begin decomposing within weeks in a composting environment
• FSC-certified paper ensures responsible sourcing, which satisfies both supply-side and demand-side sustainability criteria
• Compatible with paper mill fiber recovery — a closed-loop system that actually works at scale
Plastic Packaging: A Structurally Difficult End-of-Life Profile
• The EPA estimates that 70% of plastic packaging ends up in landfills or the environment
• Only PET (Type 1) and HDPE (Type 2) have strong recovery infrastructure — and even those face contamination challenges
• Multi-layer films, polystyrene, and mixed plastics have virtually no domestic recycling end markets
• Plastic does not biodegrade easily — it photodegrades into microplastics over hundreds of years
• MRF contamination from plastic film and flexible packaging costs municipalities hundreds of millions annually
The EPR fee schedule is, in effect, the market pricing of what consumers and municipalities have been subsidizing for decades: the hidden cost of plastic packaging waste.
What This Means for Your Brand’s P&L
The EPR fee gap is not just an environmental story. It is a cost story. And as more states adopt EPR legislation, brands that have not conducted a material-by-material audit of their packaging portfolio are going to face uncomfortable conversations with their CFOs.
Here is the math, simplified:
| Scenario | Annual Packaging Weight | Material | Estimated EPR Fee (per state) |
| Paper tube packaging | 5 tons/year | Paperboard | ~$100–$200 |
| Equivalent plastic packaging | 5 tons/year | PET/PP mixed | ~$600–$1,100 |
| Multi-layer plastic | 5 tons/year | Mixed films | ~$1,250–$2,000+ |
Illustrative estimates based on Oregon and Colorado published EPR modeling. Actual fees depend on annual PRO determinations and state-specific calculations.
For a mid-size brand shipping 50 tons of packaging per year across multiple states, the cumulative EPR fee differential between paper and problematic plastics could reach $50,000 to $200,000 annually — and that number will grow as more states come online and as PROs adjust fee schedules upward to fund expanding infrastructure.
The packaging ROI calculation has always included obvious factors: shelf presence, unboxing experience, and brand equity. EPR compliance cost is now a line item that belongs in that same calculation.
Calculate Your EPR Exposure: Interactive Tool
Use the calculator below to estimate your brand’s EPR fee exposure across different packaging materials and state jurisdictions. Enter your annual packaging volume by material type and see how a switch from plastic to paper packaging affects your projected compliance costs.
Not sure where to start? Request a custom packaging consultation — our team can help you model the EPR impact of a material transition alongside the design and brand benefits.
Paper Tube Packaging and EPR Compliance: The Natural Fit
Paper tube packaging — the kind of premium, FSC-certified, biodegradable packaging that Paper Tube Co. has been engineering since 2013 — sits at the most favorable end of every EPR fee schedule currently in effect or in development.
This is not a coincidence. It reflects what paper tubes actually are: a packaging format made from renewable, sustainably harvested fiber, manufactured with vegetable-based inks, biodegradable, and compatible with existing paper recovery infrastructure. In a world where 70% of plastic packaging ends up in landfills, paper tubes biodegrade naturally.
The EPR Compliance Credentials of Paper Tube Packaging
• FSC Certified: ensures responsible fiber sourcing, recognized by most EPR frameworks as a positive sustainability credential
• Compostable materials and biodegradable: reduces end-of-life management costs in fee calculations
• Compatible with paper MRF streams: recoverable through existing curbside infrastructure
• Can be made with mono-material structure: avoids the ‘difficult to recycle’ surcharge categories that drive up fees
• One Tree Planted partnership: every Paper Tube Co. purchase contributes to reforestation — a genuine carbon offset story
Whether you’re a brand manager at a Fortune 500 company building an EPR compliance model or an independent candle maker who just wants packaging that does not end up in a landfill, the material choice matters, explore the ready-made paper tube collection — no minimum order, ships in days.
What Brands Should Do Right Now
EPR compliance is not a 2030 problem. Oregon is already in implementation. Colorado is finalizing fee schedules. California’s program covers the largest consumer market in the United States. Brands that are still treating EPR as a future consideration are already behind.
Here is a practical checklist:
EPR Readiness Checklist for Packaging Teams
• Conduct a full packaging material audit — identify every material type in your current packaging portfolio
• Map your distribution against current EPR states: Oregon, Colorado, California, Maine, Minnesota
• Run your volume through an EPR fee calculator (see above) to model current and projected compliance costs
• Identify packaging components with the highest fee exposure — typically multi-layer films, polystyrene, and mixed plastics
• Evaluate paper-based alternatives for high-fee components — paper tubes, folding cartons, paper pouches
• Request material samples before committing to a redesign — Paper Tube Co. sample orders require no minimum and ship fast
• Document your material transitions for EPR reporting — most PROs credit proactive sustainability investments
For brands considering a full custom packaging redesign — the kind that requires structural engineering, prototype development, and production runs of 1,000 pieces or more — Paper Tube Co.’s custom packaging process starts with a quote and moves through prototyping to production in 6+ weeks.
Frequently Asked Questions: EPR Fees, Paper Packaging, and Compliance
What is an EPR fee, and who has to pay it?
An EPR (Extended Producer Responsibility) fee is a charge assessed on brands — referred to as ‘producers’ — based on the weight and material type of packaging they place into the marketplace in covered states. Any company selling products in packaging in states with EPR laws (including Oregon, Colorado, California, and Maine) is required to register, report packaging volumes, and pay fees annually into a Producer Responsibility Organization (PRO) that funds recycling infrastructure.
How much higher are EPR fees for plastic packaging compared to paper?
Based on published Oregon and Colorado EPR modeling, plastic packaging typically carries EPR fees that are 5x to 10x higher per ton than paper-based packaging. The exact differential depends on the specific plastic type: PET and HDPE carry lower fees than polystyrene or multi-layer films. Paper packaging — including paperboard, corrugated, and paper tubes — consistently occupies the lowest fee tiers in published schedules because of its high recyclability and established recovery infrastructure.
Is paper tube packaging EPR-compliant in Oregon and Colorado?
Yes. Paper tube packaging made from FSC-certified paper fiber is one of the most EPR-favorable packaging formats available. It is accepted in curbside recycling infrastructure, it biodegrades naturally, and it does not contain the multi-layer plastic constructions that drive up fee assessments. Paper Tube Co.’s packaging is FSC certified, uses vegetable-based inks,and biodegradable — all characteristics that align with the lowest fee tiers in Oregon’s and Colorado’s published EPR frameworks.
Which states currently have active EPR packaging laws?
As of mid-2025, Oregon, Colorado, California, and Maine have enacted EPR packaging laws. Minnesota, Washington, and several other states have introduced legislation that is in various stages of adoption. The trend is clear: EPR for packaging is moving from a state-by-state patchwork toward a de facto national standard, and brands that operate multi-state distribution should prepare compliance programs accordingly.
How do EPR fees affect total packaging cost calculations?
EPR fees add a per-ton compliance cost to packaging that should be factored into total cost-of-goods calculations alongside material cost, printing, and logistics. For plastic packaging, particularly in high-fee tiers like polystyrene or multi-layer films, EPR fees can add meaningfully to the effective per-unit packaging cost — especially as more states come online. Paper packaging’s low EPR fee tier reduces this compliance burden significantly, improving the total cost calculation in favor of paper-based alternatives.
Does FSC certification affect EPR fees?
FSC (Forest Stewardship Council) certification is a positive factor in several EPR frameworks because it demonstrates responsible sourcing and supply chain traceability. While FSC certification alone does not create a separate fee tier, it is recognized as a sustainability credential in Oregon’s and Colorado’s frameworks and contributes to favorable recyclability and end-of-life assessments. Paper Tube Co. uses FSC-certified papers across its product line.
What is the difference between Paper Tube Co.’s ready-made and custom packaging for EPR purposes?
From an EPR compliance standpoint, both ready-made and custom Paper Tube Co. packaging carry the same favorable material profile: FSC-certified paperboard, vegetable-based inks, compostable construction, and no multi-layer plastic laminate. The distinction between ready-made (no minimum, in stock, ships fast) and custom (1,000+ piece minimum, 6+ week lead time, full structural engineering) is a procurement and brand decision — not an EPR compliance decision.
How can I calculate my brand’s EPR fee exposure?
Use the interactive EPR Fee Calculator embedded in this post to model your annual compliance costs by material type and state. You’ll need your approximate annual packaging weight by material category (paper, PET, HDPE, PP, PS, multi-layer, etc.) and a list of states where your products are sold.
Conclusion: The 10x Gap Is a Business Decision, Not Just an Environmental One
Extended Producer Responsibility is rewriting the economics of packaging. For the first time, the environmental cost of packaging materials is being directly translated into a producer fee — a number that lives on a balance sheet, not just a sustainability report.
Paper packaging has always had the environmental argument. Now it has the financial argument too. The 10x EPR fee gap between paper and the least-recyclable plastics is not a footnote. For brands with significant packaging volumes operating across multiple EPR states, it is a material cost consideration that belongs in every packaging brief.
Paper Tube Co. has been engineering premium, eco-friendly paper tube packaging since 2013. Whether you need custom tubes for a product launch or ready-made tubes with no minimum order, the packaging that gets noticed is also the packaging that costs less to comply with. That is a combination worth designing around.
Questions about EPR compliance and packaging material selection? Connect with the Paper Tube Co. team.
* This article is for informational purposes only and does not constitute legal or regulatory advice. EPR obligations vary by state and continue to evolve through rulemaking and PRO implementation. *