The cost of a product no longer ends at the cash register
Seven US states brought new or expanded extended producer responsibility, right-to-repair, and emissions-reporting laws into effect around January 1, continuing a multi-year shift of end-of-life and disposal cost from municipalities toward the manufacturers who put the product on the shelf.
January 2026 · North America
Retrospective analysis of January 2026. Published August 2026.
On 1 January 2026, a cluster of new or expanded extended producer responsibility (EPR) and right-to-repair laws took effect across six US states, continuing a shift that began with Maine's first EPR packaging law in 2021. Vermont and Illinois both expanded battery EPR programs to cover rechargeable batteries and the larger, 4.4 to 25 pound batteries used in e-bikes and similar devices, requiring sellers and distributors, not municipalities, to fund collection and recycling. Oregon broadened its electronics EPR program to include scanners, DVD players, game consoles, routers, modems, and small servers. Colorado and Washington both brought right-to-repair requirements to consumer electronics manufactured after 2021, barring manufacturers from pairing replacement parts to a specific device's serial number, a practice that blocks independent repair even when a compatible part is available. California added a disposal fee, paid at purchase, on battery-embedded consumer products. New York's contribution to the same policy shift landed a few days earlier: a mandatory greenhouse gas reporting program covering large emitters, including landfills producing more than 10,000 metric tons of CO2 equivalent annually, took effect 25 December 2025, with monitoring plans due by September 2026 and the first annual emissions reports due June 2027.
The Signal
Seven US states brought new or expanded extended producer responsibility, right-to-repair, and large-emitter greenhouse gas reporting laws into effect around 1 January 2026, continuing the multi-year shift of end-of-life and disposal cost from municipalities to manufacturers.
Why It Matters
Seven states now have EPR laws in some form (Maine, Oregon, California, Colorado, Minnesota, Maryland, Washington), with more pending in Hawaii, Illinois, New York, and New Jersey. What changed on 1 January 2026 is that several of the earlier laws stopped being aspirational and started requiring registration, reporting, and in some cases fee payment, meaning the compliance cost these laws were designed to create is now real and due, not just legislated.
Capital Implication
Manufacturers and distributors selling into these states carry a new, quantifiable compliance liability that scales with volume sold into each state, not a one time cost, this belongs in supply chain and product-line underwriting for any company with meaningful exposure to these categories, not just in a general ESG risk register.
Development Implication
Material recovery and battery recycling infrastructure serving these states now has a more predictable, regulation-backed funding stream behind it than it did a year ago, since the laws create funded producer responsibility organizations rather than relying on voluntary participation.
What We Are Watching
- Whether the pending EPR bills in Hawaii, Illinois, New York, and New Jersey pass in 2026 and what specific product categories they cover.
- New York's already-signed reduction of its commercial organics diversion threshold to one ton per week within 50 miles of a recycler, which does not take effect until 1 January 2027, a later date than some secondary summaries of the state's 2026 changes imply.
- Compliance and enforcement data once producer responsibility organizations report their first full year of registrations and fees.
