December 14, 2023 • Nora Weiser and Rafe Morrissey
GCA: Examining a new threat for greeting card publishers

Extended Producer Responsibility (EPR) may affect your business

A new threat is emerging for greeting card publishers in the form of Extended Producer Responsibility (EPR) legislation. It has cleared a number of states, including California, Colorado, Maine and Oregon — and it is being considered in additional states each year. These laws are modeled after similar laws that have been enacted in the European Union and Canada for a number of years.

Nora Weiser GCA
Rafe Morrissey

The law’s original intent was to encourage manufacturers of consumer products to be more responsible in the design of packaging by requiring them to share a portion of the cost of recycling. Recycling costs have presented a significant financial strain on local communities. The goal was to incentivize manufacturers to use more recyclable content and minimize the amount of material in packaging. Over time, however, the Canadian law has evolved to make manufacturers responsible for all of the costs of the collection and recycling of packaging, with limited exclusions for highly recyclable content such as paper.

The laws in the first four U.S. states seem to reflect the increased scope of the new Canadian approach. While all the laws exclude small businesses with less than $5 million in gross revenue, they set a troubling precedent, and such exclusions have a tendency to be reduced over time. In Oregon’s case, the proposed regulations have expanded well beyond the stated intentions of the bill sponsors in the law. They did not intend for the legislation to cover greeting cards and stated so in a letter to the Department of Environmental Quality. To date, however, the department has refused to approve such an exclusion.

The Greeting Card Association (GCA) has recently engaged in Oregon to push for the exclusion of greeting cards on the basis that they were never intended to be covered by the laws. Cards have a much different profile in the waste stream, since many are retained for years as keepsakes. GCA members around the country are weighing in, but this is just one state in a growing list, and we are preparing to assist our members in engaging as new states consider such legislation.

GCA has long supported sustainable practices, and paper remains one of the most recyclable media. The stationery industry encourages sustainability and actively seeks ways to reduce waste. But one-size-fits-all approaches that place the entire burden of waste collection on manufacturers — and eliminate any incentive for greater recyclable content — are merely unfair cost-shifting measures that cause more harm than good.

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