Executing on EPR

Extended producer responsibility laws for paper and packaging are new to the U.S., with seven states having passed such legislation since the start of this decade: Maine, Oregon, Colorado, California, Minnesota, Maryland and Washington. While each state’s law has unique elements, one common thread is the role of the producer responsibility organization, or PRO. For California, Colorado, Oregon, Minnesota and Maryland, that PRO is the Circular Action Alliance (CAA), a nonprofit founded by major packaging producers, including Amazon, The Coca-Cola Co., Colgate-Palmolive, Danone, Ferrero, General Mills, Keurig Dr Pepper, The Kraft Heinz Co., L’Oréal, Mars Inc., Mondelez International, Nestlé USA, Niagara Bottling LLC, PepsiCo, Procter & Gamble, SC Johnson, Target and Walmart.

Jeff Fielkow has served as CEO of CAA since August of 2024. His 30-plus years of business experience include roles as president and CEO of ID Images LLC, a leading manufacturer of converted label products; multiple executive positions within Tetra Pak Inc., one of the world’s largest food-processing and packaging companies; and 15 years in a variety of leadership and operational roles within the recycling industry, including with material recovery facility (MRF) operators ReCommunity Inc. and WM Inc.

“I’ve spent my entire career working across the packaging and recycling value chain, from operations and manufacturing to sustainability leadership and startups, so I’ve seen firsthand where systems fail and what it takes to make them succeed,” he says of what attracted him to CAA. “EPR for paper and packaging creates a unique opportunity for the producer-led private sector to modernize municipal recycling at scale.”

Fielkow says he joined CAA to build and scale an organization capable of turning regulatory compliance into real environmental and economic outcomes.

In the following interview, Fielkow shares his perspective on the EPR implementation journey and how CAA is addressing the challenges it is encountering.

Recycling Today (RT): What do you plan to accomplish as CEO of CAA this year?

Jeff Fielkow (JF): This year is about execution. Our focus is disciplined and high-impact: delivering a full year of operations under Oregon’s Recycling Modernization Act; launching Colorado’s program this June; submitting California’s program plan by midyear; entering Washington with more than 2,000 producers; and supporting emerging states like Minnesota with registration and readiness. At the same time, we’re building enterprisewide data, audit and reporting systems; scaling our team with deep operational and regulatory expertise; and creating consistency across states so producers have one clear way of working, even in a fragmented regulatory landscape.

Success will be measured by trust earned, programs launched and tangible improvements to recycling access, infrastructure and material recovery.

RT: How do your previous roles contribute to your understanding of what it takes to make residential paper and packaging recycling programs successful? 

JF: My career has given me a full-system view of what makes recycling programs succeed. I’ve led global manufacturing and packaging businesses, built recycling and recovery organizations and held senior sustainability and operations roles across multiple regions. That experience helps me understand the incentives, constraints and decision-making realities at every point in the supply chain. 

Those roles reinforced three fundamentals. First, access and infrastructure matter most—recycling only works when people have convenient, equitable ways to participate, supported by modern collection and processing systems. Second, clear and consistent messaging is critical; confusion drives contamination, lowers material quality and erodes trust. Third, strong end markets are essential—without reliable demand for recycled material, even well-designed programs fail.

Equally important, durable progress requires collaboration. Co-founding the Carton Council showed that competitors can align around shared responsibility and measurable outcomes when the framework is credible and well-governed. That lesson shapes how I lead CAA, positioning us as a trusted partner and ensuring resources are directed where they deliver meaningful, systemwide results rather than incremental gains.

RT: What is the biggest hurdle CAA has had to overcome in the implementation process so far? 

JF: The first major hurdle was producer participation. Paper and packaging EPR was new in the United States, and thousands of producers needed to understand new legal, reporting and financial obligations within compressed timelines. That required extensive education and direct engagement. More than 3,000 producers are now registered, reporting and paying into CAA programs, creating the foundation these systems require.

The next challenge was building credible program plans under highly condensed timelines with limited validated data. We addressed this by applying deep operational expertise and leading comprehensive needs assessments. CAA built the analysis required to design programs grounded in real system conditions.

Educating and engaging the haulers and recycling community has been equally essential. These programs succeed only when operational partners understand how EPR changes funding, performance expectations and accountability. The progress has been strong and continues as programs now move into execution.

Finally, responsible end markets remain the most complex and consequential challenge, particularly for materials such as flexible packaging. Addressing this is critical to long-term success.

RT: Tell me more about how CAA is organized and the roles of the executive directors at the state level. 

JF: CAA’s strategic operating model is designed to deliver consistency and efficiency across states while preserving local flexibility. At the core of this model are national services that provide essential capabilities such as compliance systems, data analytics, producer registration, contracting and communications on a shared platform. 

This national infrastructure allows CAA to scale efficiently. New states can be added without rebuilding systems or replicating teams, enabling rapid implementation and predictable costs.

State leadership remains critical. The executive director in each state leads program implementation and builds local teams to engage municipalities, haulers, recyclers and community partners. This structure allows us to honor local conditions while operating within a consistent national framework. 

The result is a balanced model that combines centralized strength with local expertise, delivering operational excellence and a seamless experience for producers.

RT: What challenges related to responsible end markets is CAA working to address? 

JF: Responsible end markets are the backbone of a functioning circular economy. Without [those end markets], recycling lacks credibility and accountability. The purpose of responsible end markets is to create transparency and trust by verifying that collected materials are sent only to facilities that meet environmental integrity and labor standards.

One of the primary challenges is end-market reluctance driven by concerns around data privacy, confidentiality and protection of trade secrets. State EPR laws require verification, but that verification must be balanced with commercial realities. 

CAA is addressing this by building an independent responsible end market verification framework supported by third-party reporting. Verification focuses on outcomes and compliance, not competitive information.

More than 10 cross-functional stakeholders are actively serving on the standards development committee to ensure the framework is practical, credible and scalable across states. Harmonization creates predictability, giving recyclers and manufacturers confidence to invest in processing capacity and recycled content.

RT: What role can CAA and EPR play in helping to expand the materials accepted in a program? 

JF: EPR gives us the structure and funding to expand the types of materials accepted in recycling programs in a consistent, sustainable way. Today, material acceptance varies widely from one community to the next, and local programs often struggle to keep pace with market shifts. EPR allows CAA to take a more holistic, systemwide approach, leveraging existing infrastructure, building regional and national economies of scale and ensuring that end markets, sorting capacity and collection systems are aligned. Through producer-funded investments, ecomodulated fees and coordinated education, we can support more recyclable packaging designs, strengthen responsible end markets, upgrade sorting and collection infrastructure and help residents understand what can and cannot be recycled.

Our role is to bridge the needs of producers, local governments and recyclers so more materials can be collected, sorted and actually recycled. 

RT: How can EPR address challenges related to away-from-home recycling? 

JF: EPR creates the structure and funding needed to finally improve recycling outside the home, where bins are inconsistent, infrastructure is under-resourced and contamination rates are high. EPR allows producers to invest in standardized public-facing collection systems, clearer signage and better processing capacity, which leads to higher recovery and better material quality. It also enables coordinated education campaigns, so people see consistent messaging where they live, work, play and learn. With producers accountable for outcomes, away-from-home recycling can be modernized in a way municipalities have never had the resources to do on their own. 

RT: How can EPR programs avoid oversupply situations? 

JF: Oversupply is a valid concern, but EPR programs are designed to prevent it by managing both the quality and the destination of recovered materials.

The biggest bottleneck in recycling isn’t usually too much material; it’s contaminated material that end markets can’t use. By investing in MRF upgrades and better sorting technology, EPR ensures we produce high-quality feedstock that consistently moves, even in volatile markets.

At the same time, EPR creates the long-term volume certainty needed to expand domestic processing capacity, so demand grows in step with supply.

Finally, ecomodulated fees discourage hard-to-recycle packaging and shift the material mix toward formats with strong end markets.

In short, EPR aligns supply with real demand, ensuring more material gets recycled without overwhelming the system. 

RT: What are the strengths and weaknesses of the various EPR legislation CAA is working to help implement? 

JF: The core strength of these laws is they place responsibility and funding with producers and establish performance targets that drive accountability. They create conditions for long-term system improvement.

The challenge is fragmentation. Each state has different definitions, timelines and scopes. That complexity increases cost and operational risk if not managed carefully.

[Of the EPR laws that have been passed] Oregon’s law stands out for its clarity and ambition. Colorado’s statute is notable for requiring full funding of recycling services, which accelerates infrastructure upgrades.

Our role [at CAA] is to make each law succeed while building as much alignment as possible across states.

RT: What is CAA doing to avoid stranded assets in the various states it serves as PRO? 

JF: Protecting producer investment is fundamental to our role. We take a disciplined, data-driven approach so capital is directed where it delivers durable value. Every decision begins with a clear assessment of existing assets. We evaluate whether infrastructure can meet program requirements, is appropriately located and can be upgraded to perform as systems evolve.

Not all assets will remain viable. Facilities that cannot meet state program requirements, are poorly located for long-term material flows or cannot be retrofitted to achieve required performance levels will not be sustained.

New investments are grounded in material flow analysis and long-term projections to ensure assets are sized for future demand.

When transitions are necessary, we work closely with jurisdictions, haulers, recyclers and producers to phase changes over time.

By aligning infrastructure decisions with verified data and state timelines, we avoid stranded assets and build resilient recycling systems.

RT: Once implemented, when do you expect to see recycling rates increase? 

JF: Recycling system improvement is cumulative, not immediate. The first gains come from building the right foundation, upgrading MRF infrastructure, expanding access and improving education so residents know what and how to recycle. Early progress often shows up as lower contamination and more consistent material quality, followed by higher capture as participation grows.

Strong end markets must also be in place to sustain long-term progress.

In Oregon, we expect measurable improvements within two years of launch, with statutory targets of 25 percent plastic recycling by 2028 and 50 percent by 2040.

Colorado projects nearly doubling its recycling rate by 2035.

The path is deliberate, and the results are designed to last. 

RT: Are stakeholders taking an adversarial approach or are they collaborating? 

JF: Interest holders are increasingly choosing collaboration. The recycling system is too complex for any one group, producers, haulers, MRFs, local governments or NGOs [nongovernmental organizations], to solve in isolation. EPR has created a shared framework where each party’s role is clearer, incentives are aligned and collaboration produces better outcomes than conflict. 

We’re also seeing strong interest in sharing ideas, lessons learned and best practices from established programs, so we can build an even stronger, more consistent system nationwide.

Most stakeholders recognize that collaboration ultimately benefits everyone, especially the communities we all serve. 

RT: How crucial are recycled content requirements? 

JF: Recycled content requirements are an important tool, and CAA’s role is to build programs based on what each state’s statute directs. Not every material has the same recycling pathways or access to infrastructure, so end market development will look different across product types. Our focus is on strengthening responsible end uses … where they meet performance, health and safety standards. Through ecomodulated fees and market-driven incentives, we aim to support increased recycled content use as supply, quality and statutory direction allow.

RT: How important are ecomodulation and design for recycling? 

JF: Ecomodulation and design for recycling are important tools, but they’re part of a broader system. Packaging design must balance many factors, including product protection, safety [and] performance, not just recyclability. That’s why we take an iterative approach: incentivizing changes where recyclability is achievable today while gathering data to understand where the real barriers exist for more complex formats.

As producers and service providers begin reporting into EPR programs, we’ll have the data needed to refine our fee signals and support targeted investments in collection, sorting and recycling infrastructure. Over time, ecomodulated fees will help guide design decisions and strengthen the overall system without compromising product integrity or safety.

Jeff Fielkow is the CEO of Circular Action Alliance (CAA). For more information on CAA, visit https://circularactionalliance.org.