- AHAM supports EPR programs that focus on packaging that enters household or curbside recycling streams.
- Packaging used for durable goods, including major home appliances, should be excluded from EPR obligations.
- EPR policies should focus on fast-moving consumer goods, the main contributors to residential packaging waste.
- Manufacturers have a right to know the final destination of their packaging materials.
Several states and Canadian provinces have implemented extended producer responsibility (EPR) policies, making manufacturers responsible for the cost of recycling packaging materials. Home appliance manufacturers support EPR programs that are sensible, practical and focused on real environmental impact.
Packaging plays a vital role in protecting home appliances during shipping, storage and delivery. Unlike packaging used for fast-moving consumer goods, which is designed for retail settings and is often processed by municipal recycling systems, appliance packaging is specially designed to protect appliances during storage and transportation. This packaging typically does not reach the home and often bypasses municipal recycling systems altogether. One-size-fits-all approaches that fail to distinguish between the types of packaging create inefficiencies and significant regulatory burdens without a measurable environmental benefit.
Appliance manufacturers already have strong financial incentives to minimize packaging waste. The fee structures within EPR programs must reflect the full life-cycle impact of materials. EPR programs must avoid penalizing packaging that is functionally necessary and not part of consumer waste streams.
States that are pursuing EPR policies should strive to incorporate transparency about the final destination of packaging material, which can affect fees and compliance, align their requirements with other states to reduce regulatory complexity.
