EPR affects every CPG category differently. Here's where the fee exposure actually sits, and what you can do about it.

EPR compliance isn't one-size-fits-all. The fee exposure that's most relevant to a supplement brand looks very different from the one keeping a beverage brand's packaging team up at night. Below we've mapped out the primary considerations by category: where the risk concentrates, where the quick wins are, and what we're watching.

Supplements and Nutraceuticals

The supplement category is actually reasonably well-positioned in its primary packaging, with one significant exception.

HDPE and PET bottles are in good shape. The dominant format for capsules, tablets, gummies, and powders grades at the A or B level depending on color and PCR content. Natural (unpigmented) HDPE is at the top of the recyclability range. Clear PET is similarly favorable. Base fee exposure here is low.

Flexible pouches are the primary exposure. Multi-layer laminated pouches used for protein powders, pre-workout blends, and greens products grade at the F level under eco-modulation across all active state programs. There is no viable curbside recycling stream for these formats anywhere in the seven EPR states. Every gram carries the maximum penalty surcharge.

Additional exposure: PVC closures and liners. Multi-component packaging incorporating PVC closures or liners is a less common but meaningful source of Malus fees for certain supplement formats.

Where to focus first: Identify your flexible pouch volume by SKU and state of sale. That's where the fee exposure concentrates. The bottle side of the portfolio is likely already in reasonable shape, but confirm PCR certification to capture any available discounts.

Personal Care and Beauty

Personal care and beauty brands are navigating a dual-pressure scenario in 2026 that's worth understanding clearly, because the two forces are pulling in opposite directions.

Aluminum components are EPR-friendly but tariff-exposed. Aluminum closures and components grade at the B level under most program frameworks: aluminum is highly recyclable with a well-established end market. That's good news for EPR. A format that looks favorable from a compliance standpoint is getting more expensive from a raw materials standpoint at the same time.

Multi-layer laminate tubes and flexible pouches are the main EPR exposure. Common in complexion products, hair treatments, and single-use formats, these grade at the F level under eco-modulation and carry the highest penalty surcharges in the category. For brands using these formats at volume, the fee impact over a full year can be significant.

Refillable formats offer the biggest reduction and a credit window is open now. Brands in Oregon that switch from single-use plastic to refillable formats are eligible for Bonus C credits, with a May 31, 2026 submission deadline. If you have a refill concept in development or already live, this is worth exploring immediately.

Where to focus first: Audit your laminate tube and flexible pouch volume. Model the fee differential between current formats and mono-material alternatives. If you have a refill concept at any stage, look at the Oregon Bonus C window before it closes.

Food and Condiments

Glass grades at B, a reasonable starting position. Glass jars are widely recyclable with minimal sorting disruption, making them one of the more EPR-resilient primary packaging formats for a food or condiment brand.

The fee exposure in this category concentrates elsewhere:

E-commerce foam inserts. EPS foam grades at F across all programs: no curbside end market, disrupts sorting lines, maximum Malus surcharge. Molded pulp inserts are a direct F-to-B upgrade for most applications and are increasingly cost-competitive. This is one of the more accessible wins in the category.

Flexible pouch formats. Sauces, spreads, condiment sachets, and single-serve squeeze formats in multi-layer laminate structures carry the same F-level exposure as flexible pouches in any other category.

Non-recyclable overwraps. Secondary and tertiary packaging that can't be processed by the recycling system adds to fee exposure even when the primary container grades well.

Where to focus first: E-commerce foam replacement is often the fastest ROI in this category: molded pulp is available, cost-competitive, and moves the fee grade significantly. Flexible pouch volume is the bigger structural exposure.

Cannabis and CBD

Cannabis presents a genuinely complicated EPR compliance picture, and it deserves some nuance.

Start with geography. Unlike a supplement brand with nationwide retail distribution, cannabis brands operate only in the states where they're licensed. That changes the math considerably. If California is one of four markets where your cannabis brand sells, it's not representing 10–15% of your revenue the way it might for a CPG brand with national distribution. It could be 25%, 40%, or more. That concentration means California's EPR fee structure hits differently: compliance costs that a broadly distributed brand can absorb across dozens of markets land with much more force when your entire addressable footprint is a handful of states. The smaller your state footprint, the higher the EPR exposure per dollar of revenue, and the more urgency there is to get ahead of it.

Child-resistant packaging adds another layer. CR requirements can be met with rigid formats (jars, tubes with child-resistant closures) that tend to be more EPR-friendly, or with multi-layer flexible formats that grade at the F level under eco-modulation. As EPR fee exposure on those formats rises, the pressure to find CR-compliant alternatives that don't carry Malus penalties is increasing.

This is an active area of packaging development. The intersection of child-resistance engineering and EPR-compliant design is one of the more interesting problems in the space, and formats are emerging that address both requirements without defaulting to multi-material laminates. It's not a fully solved problem, but it's closer than it was two years ago.

Where to focus first: This is a category where the constraints are real and the geography is decisive. We're staying close to the development of CR-compliant alternatives. If this is a live question for your brand, it's worth a direct conversation as the right path depends on your specific format mix and state footprint.

If you’re interested in learning more about the nuances that surround Cannabis packaging, check out our recent blog on the topic.

Beverage

Aluminum cans and PET bottles are in a strong position. Aluminum is highly recyclable with a favorable eco-modulation grade. Clear PET grades at the A level under most frameworks. Certified PCR content in PET earns direct fee discounts. Given how commercially established PCR PET is, this is one of the more accessible compliance wins available to beverage brands.

Flexible and multi-layer pouch formats are the primary exposure. Functional beverages, kids' drinks, and on-the-go formats using multi-layer pouches carry F-level exposure. This is the highest-exposure area in beverage EPR.

PVC shrink sleeves are a straightforward fix. PVC shrink sleeves grade at F, because they contaminate the PET recycling stream at the wash stage. Switching to PET shrink sleeves is typically cost-neutral, operationally straightforward, and moves a label format from Grade F to Grade B. One of the cleanest wins in the category.

Where to focus first: Check your shrink sleeve spec. If you're running PVC, the switch to PET is low-friction and the fee impact is immediate. Then look at your flexible format volume: that's where the bigger structural exposure sits.

Closing Thoughts

Each of these categories has its own exposure profile, but they all share the same underlying dynamic: the material choices built into your packaging today are directly connected to the compliance fees you'll be paying as these programs ramp up. And while the eco-modulation logic is consistent in principle, the scorecard isn't identical across every state: each active program has its own fee schedule, its own incentive structure, and its own list of what it rewards and penalizes. 

Therefore, a packaging change that earns a meaningful fee reduction in Oregon may be neutral in Colorado and irrelevant in California. That gap matters when you're evaluating whether an investment is worth making. For example, a refill system might look compelling on paper, but if only one of your three markets actively incentivizes it, and the cost of building that system is substantially higher than simply increasing PCR content in your current format, the math may never work. The right packaging decision is one that requires various considerations and calculations. If you’d like to learn more, please download our EPR guide, or setup some time to chat and we’d be happy to help partner with you before you commit to a direction.

If you want to talk through the specifics for your category and format mix, book a call with our team at sourcem.com.