Extended producer responsibility for packaging programs require a heavy lift to move from law to implemented program. State agencies, consultants and other groups are hiring to meet the demand in 2026 and beyond – though there can be strong competition for a limited pool of applicants with expertise. 

The programs, which have been adopted in seven U.S. states, have a complex implementation period. Some programs, such as Maine’s, left much to be hashed out during that rulemaking process. Others, like Colorado, had a more prescriptive law. 

States staff up

Wolf Kray, materials management unit leader at the Colorado Department of Public Health & Environment, said via email that appropriate staffing is essential to ensure “there are adequate resources available to successfully navigate the many complex issues associated with developing and implementing a producer responsibility program at the state level.” 

In Colorado, HB 22-1355 authorized the department to add one full-time employee in 2022 to oversee and administer the program, and one more full-time employee in 2025 to oversee compliance and enforcement.

Looking to the newest state to adopt packaging EPR, Kara Steward, Recycling Market Development Center coordinator for the Washington Department of Ecology, has been dealing with an extra wrinkle: a hiring freeze. The state is currently facing a budget deficit, and any new hires require special permission. Two employees from other programs have been pulled in to get the program started, and Steward is one of them. 

“We had to start the program and grab from people who had jobs to help out. That’s sort of where we’re at,” Steward said. “I have a full-time job doing other things … It worked out okay, but it does put some program work to the side for a short period of time until we can hire and train someone up.” 

The packaging EPR program did get permission to hire one full-time position, which it was in the process of filling at the end of this year, but “absent the hiring freeze, we would have put out those announcements earlier,” Steward added. 

The department estimated that program implementation would need between three and eight staff positions. Steward said three of those are intended to be permanent, “from start to forever,” while the other roles are more for the first several years of implementation. An additional one or two hires in the next six months is the goal, and the department is waiting for permission from the head of the agency to do so. 

For the current employees filling in, Steward said it’s been helpful to be the youngest program, as “there are six other great states who have tested the water ahead of us.” 

In particular, looking at how other states have formed advisory boards and what those boards have covered in the first year has been useful. 

Similarly to other states, the eventual producer responsibility organization will reimburse Washington for program start-up costs, then take over funding obligations, but in the meantime, “it's a real challenge for the state to cover those first couple of years,” Steward said. The state will choose a PRO by March.

In California, CalRecycle plans to add 62 permanent staff over six fiscal years. Hiring started in the 2022-2023 budget cycle. 

“CalRecycle has hired the majority of the staff, including scientists, analysts, administrators, legal staff, and managers to help carry out research, coordinate with program participants, and ensure the program meets the law’s ambitious goals and deadlines,” an agency spokesperson said over email. 

Mallory Anderson, packaging EPR coordinator for the Minnesota Pollution Control Agency, said their program has 2.5 full-time employees assigned to administer the Packaging Waste and Cost Reduction Act, but that could increase in coming years if needed. 

“This currently involves support for program oversight, data management, advisory board support and completing the needs assessment,” she said. “The program is currently in the data-gathering phase and has not yet moved into full implementation. The agency will continue to assess staffing needs as the program evolves.” 

Agencies in the other packaging EPR states — Maine, Oregon and Maryland — did not respond to requests for comment.

Producers look for help

On the producer side, that help is also in high demand from PRO Circular Action Alliance — which was on a major hiring spree in 2025 — as well as law firms, consultants and brands.

Consultant Michael Washburn co-founded EPR Academy, which provides online classes on EPR basics and compliance. Washburn said there’s currently “stiff competition for a limited pool” of people who are well-versed in EPR. “There just isn't enough of a bench.” 

Producers in Oregon, where the EPR program is active, have started to receive non-compliance notices, Washburn said, which is driving demand as the fines could range into the millions. 

Brands are also looking to hire compliance managers, he said, with the growing recognition that EPR compliance means more than collecting and submitting data a few times per year. 

“People focus on this as a data exercise, which is absolutely true, but it's incomplete,” Washburn said, pointing to the learning, scoping, relationship building, budgeting and internal and external communication that’s needed. “There are demands being placed on enterprises for which they do not currently have capacity and do not have knowledge.” 

He said he’s heard the same from others in the field and has also seen a proliferation of tools marketed to companies to help with the data side of things.

“That’s great, but you can’t use a data widget if you don't have a data owner, if you don't have a compliance manager, if you don't have the internal infrastructure to look at this in a holistic way,” he said. “And that’s all just to get to basic compliance, let alone thinking about it as a strategic opportunity.” 

More training is needed to create a workforce with the “nuanced specialized knowledge that’s required to interpret these regulations, support producer compliance, support implementation,” Washburn said, adding that he could see business schools adding EPR classes or even minor tracks in the near future. 

On the producer side, multiple trade groups said they did not have a sense of how and if brand companies were staffing up in response. 

Washburn said a communication problem he sees often is that larger companies don’t have strong – or sometimes any – knowledge sharing about EPR compliance between branches. 

“You would think there would be an advantage to the global companies because they've been doing this elsewhere but it's not true,” he said. 

Artificial intelligence tools could be helpful; Washburn said his team uses AI to help match packaging to covered material lists. But they’re also not specifically trained for EPR and could introduce serious, and expensive, errors, he warned. 

“To get to a place where AI is a big part of the solution we have to do the first things first,” he said, “which is to have a much larger cadre of trained experts, even to go out and build and teach the tools.”