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EPR 2.0: What OEM Leaders Need to Know Now

05/13/26

If Extended Producer Responsibility (EPR) feels more complex than it did a few years ago, you’re not imagining it.

In a recent Dynamic SPARK podcast conversation, Amanda Buros, VP of Recycling, Sales & Corporate Responsibility at Dynamic Lifecycle Innovation, sat down with Jason Linnell, Executive Director of the National Center for Electronics Recycling (NCER) to unpack what’s really changing across the EPR landscape—and what it means for OEMs trying to keep up.

One thing became clear quickly:

EPR isn’t expanding in the way many expected. It’s evolving.

Across the U.S., we still have 26 electronics EPR programs. There is no major wave of new legislation and no federal framework on the horizon.

And yet, for OEMs, the environment feels more dynamic and more demanding than ever.

The Shift: From Expansion to Evolution

Early EPR programs were built to remove large problematic devices from the waste stream, and they were measured on volume and used volume targets to measure success.

But that model is starting to show its age.

Today, the device mix has changed. Large, heavy legacy devices are declining, while smaller, more complex electronics are increasing.

That shift is changing how success is measured.

Instead of focusing only on weight, programs are emphasizing:

  • Accessibility
  • Convenience
  • Consumer participation

We haven’t seen a lot of activity in terms of new states passing laws. What we are seeing is states modifying and evolving the programs that already exist.


— Jason Linnell, NCER

What’s Driving EPR Program Changes

Several forces are shaping this next phase of EPR:

Changing Material Streams

Devices are lighter, more diverse, and more complex to process. That impacts both cost and program design.

Circularity & Critical Materials

There is growing focus on recovering valuable materials domestically and supporting circular supply chains.

Packaging EPR Influence

New packaging laws are expanding the scope of EPR—and influencing how electronics programs evolve.

Operational Reality

Collectors are already handling a mix of covered and non-covered devices. Expanding scope is often a practical solution, not just a regulatory one.

 

Case in Point: Oregon’s EPR Evolution

Oregon offers a clear signal of where EPR programs are headed.

Recent changes include:

  • A shift to a PRO-led model
  • The end of the state contractor structure
  • New convenience-based requirements
  • Expanded product categories

 

This is more than a program update. It is a structural shift in how responsibility is organized.

 

What This Means for OEMs

EPR compliance is no longer a check-the-box exercise.

Leading OEMs are:

Staying Ahead of Product Scope

Covered categories are expanding—and not always consistently.

Understanding the Full System

Not just requirements, but how materials move and where costs originate.

Choosing the Right Partners

Recycling partners now play a critical role in compliance and performance.

Staying Engaged

Proactive involvement with organizations like NCER and ERCC helps reduce surprises and improve outcomes.

 

It’s not happening in a vacuum. There are other industries, like packaging and batteries, driving a re-evaluation of how EPR programs work.


— Jason Linnell, NCER

The Bigger Picture: EPR Beyond Electronics

EPR is expanding beyond electronics into:

  • Packaging
  • Batteries
  • Other material streams

This brings new expectations around:

  • Recycled content
  • Circular design
  • Responsible end markets
  • Repairability

What happens in these areas will influence electronics next.

 

Where We Go from Here

EPR is entering a new phase:

Optimization. Integration. Accountability.

For OEMs, that means:

You don’t just need compliance.
You need clarity and confidence in how your program operates.

 

Do You Have a Clear View of Your EPR Program Today?

If you’re unsure how your program is performing across states, partners, and evolving requirements, it may be time to take a closer look.

Schedule your EPR program review to evaluate your approach, identify gaps, and build a clearer, more confident path forward.

 

Resources Mentioned in This Conversation

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