At a glance
- Status
- Start-up. PRO membership required since July 1, 2025. Full program from 2029.1
- Law
- Minn. Stat. §§115A.144–115A.1463 (2024).
- PRO
- Circular Action Alliance.
- What's covered
- Packaging, including food packaging, and paper products.
- Small-producer exemption
- Under $2M global gross revenue, or under 1 ton.
- Next milestone
- Needs assessment due December 31, 2026.
- Penalties
- Up to $25,000 per day, rising to $100,000 for repeat violations.
Who's covered
Minnesota covers packaging, including food packaging, and paper products.2 The producer is identified in this order:2
- The manufacturer, if the product is sold under its own brand or carries no brand.
- The licensee, a company licensed to make and sell the product under someone else's brand.
- The brand owner.
- The US importer of record, if none of the above is in the United States.
- The first distributor into the state.
For online sales, shipping packaging belongs to “the person that packages the item to be shipped to the consumer.” Franchisors are the producer when they have franchisees in Minnesota. Responsibility can be assigned to another company by mutually signed agreement, if that company joins a registered PRO and the PRO receives written certification.2 See Are you the producer?
Exemptions
A de minimis producer is exempt: one that introduced under 1 ton of covered materials in its most recent fiscal year, or had global gross revenue under $2 million.2 Government entities and 501(c)(3) and (c)(4) organizations are also excluded.
Exempt materials include packaging for infant formula, medical food and fortified nutritional supplements; FDA-regulated drugs, medical devices and medical equipment; animal drugs; FIFRA-regulated pesticides; hazardous or flammable products; refillable propane containers; paint covered by the paint stewardship program; and business-to-business packaging that never reaches consumers.2
What you have to do, and when
Minnesota is in its start-up phase. Producers must already belong to a PRO, but full reporting and fees come later.1 Circular Action Alliance is the registered PRO.3
| Date | Milestone |
|---|---|
| July 1, 2025 | Producers must be members of a registered PRO |
| May 31 and July 1, 2026 | CAA's deadlines for a simplified 2025 data report and registration with brand lists |
| December 31, 2026 | First statewide needs assessment due |
| July 1, 2028 | State publishes lists of recyclable and compostable materials |
| October 1, 2028 | PRO stewardship plan due |
| January 1, 2029 | No covered materials sold without an agreement under an approved plan |
| February 1, 2029 | PRO reimburses at least 50% of service provider costs (75% in 2030, 90% in 2031) |
| January 1, 2032 | All covered materials must be reusable, refillable, recyclable or compostable |
Sources: Minn. Stat. §§115A.1448, .1450, .1453, .1455; CAA Minnesota.1,3,4,5
What it will cost
Fees haven't been set. The statute requires them to be eco-modulated, with incentives that include reducing toxic substances, and reusable packaging is charged once, when it enters the market.6 The PRO must reimburse local recycling providers for a rising share of their costs from 2029.4
The state hasn't set performance targets yet either. In 2026, the Minnesota Pollution Control Agency presented draft ranges, including a recycling rate of 50–55% within five years and 55–65% within ten, and reuse of 6–14% within ten years. These are proposals, not requirements.7,8
Enforcement
Minnesota has some of the highest penalties of any state:9
| Violation | Penalty |
|---|---|
| First | Up to $25,000 per day |
| Second within 5 years | Up to $50,000 per day |
| Third or later | Up to $100,000 per day |
What's changing
- Needs assessment. The draft statewide needs assessment is open for comment until November 13, 2026. It will set the baseline for targets and costs.10
- Rules. MPCA began rulemaking in 2026, but no proposed rule had been published as of our review date.11
What to do now
- Confirm your CAA membership. It has been required since July 2025.
- Check the de minimis tests using global revenue.
- Review your packaging against the 2032 design requirement. Anything that won't be reusable, recyclable or compostable needs a plan.
- Comment on the needs assessment if your industry has specific concerns.
Not sure where you stand?
Tell us about your products and where you sell. We'll reply in writing with the states where you're obligated, the rule that puts you there, and the deadline. Free, and no call required.
Related guides
Sources
- Minn. Stat. §115A.1448 (producer requirements). revisor.mn.gov
- Minn. Stat. §115A.1441 (definitions). revisor.mn.gov
- Circular Action Alliance, Minnesota. circularactionalliance.org
- Minn. Stat. §115A.1455 (reimbursement of service providers). revisor.mn.gov
- Minn. Stat. §115A.1453 (exemptions; recyclable and compostable lists). revisor.mn.gov
- Minn. Stat. §115A.1454 (producer fees). revisor.mn.gov
- MPCA, needs assessment information session slides (draft target ranges). PDF
- Minn. Stat. §115A.1451 (performance targets). revisor.mn.gov
- Minn. Stat. §115A.1462 (enforcement and penalties). revisor.mn.gov
- MPCA, 2026 needs assessment public comment. comment.pca.state.mn.us
- Minnesota Pollution Control Agency, Packaging Waste and Cost Reduction Act. pca.state.mn.us
What changed
- October 2, 2026 First published.
General information, not legal advice. This guide summarizes laws, rules and program documents as we read them on the review date above. These programs change often, and how a law applies depends on your products, contracts and facts. For a formal opinion, consult counsel. Producer Desk is not a law firm.