Question 1

What are EPR packaging laws, and why do they matter for manufacturers?

Accepted Answer

Extended producer responsibility (EPR) packaging laws make manufacturers financially and operationally responsible for managing their packaging waste at the end of its life. Under these laws, producers must fund recycling, reporting, and waste management programs through Producer Responsibility Organizations (PROs).In the U.S., EPR is state-driven, meaning compliance varies by state. Manufacturers must track packaging data, report to the appropriate PRO, and pay eco-modulated fees based on recyclability and material composition.EPR laws support a circular economy, reduce landfill waste, and help manufacturers meet sustainability goals.

Question 2

How do manufacturers comply with EPR packaging requirements?

Accepted Answer

Compliance typically involves four key steps:Register and join the appropriate Producer Responsibility Organization (PRO).Track and report the types, weights, and recyclability of packaging materials placed on the market.Pay PRO fees, which may vary based on packaging recyclability (eco-modulation).Meet recycling and content targets — for example, post-consumer recycled content in plastics and paper.Manufacturers must also monitor updates to avoid gaps in compliance across states. Using centralized EPR compliance software helps automate reporting and ensures data accuracy across jurisdictions.

Question 3

How can manufacturers prepare for EPR compliance and avoid penalties?

Accepted Answer

The best way to avoid EPR compliance risks is through proactive preparation and consistent data management. Start by identifying where your products are sold, what materials your packaging uses, and whether those materials are in scope for EPR programs. From there, establish internal tracking processes and join a Producer Responsibility Organization (PRO) early.Manufacturers can also reduce costs and risk by designing recyclable or reusable packaging, centralizing reporting data, and automating updates across states as new regulations emerge. Investing in an EPR compliance platform helps ensure you meet reporting deadlines, maintain audit-ready documentation, and stay ahead of rapidly changing state requirements.

Question 4

How does Assent help manufacturers manage EPR packaging compliance?

Accepted Answer

Assent helps manufacturers simplify and scale their EPR compliance across multiple U.S. states. The Assent Sustainability Platform centralizes packaging data, automates reporting to Producer Responsibility Organizations (PROs), and keeps you ahead of evolving requirements.With Assent, you can track material composition, calculate packaging weights, and generate audit-ready reports that align with state-specific EPR laws, from California’s SB 54 to Colorado’s HB 22-1355. The platform also provides real-time regulatory updates, so you’re never caught off guard by new reporting deadlines or scope changes.

Question 5

What are the Minnesota PFAS reporting rule requirements?

Accepted Answer

Minnesota’s final PFAS reporting rule requires manufacturers to report all products containing intentionally added PFAS that are sold, offered, or distributed in the state, including online sales. The rule covers a broad product scope, including fluoropolymers such as PTFE. Manufacturers must submit detailed product information, PFAS functions, and concentration ranges through Minnesota’s new PRISM reporting system. A one-time $800 fee per manufacturer applies, and most reported information will be publicly accessible unless trade-secret protection is approved.

Question 6

What is PRISM for PFAS reporting?

Accepted Answer

PRISM (PFAS Reporting and Information System for Manufacturers) is Minnesota’s new online platform for submitting PFAS product data. Launching January 2026, PRISM will serve as the centralized system for Minnesota’s PFAS reporting program and is designed to support multi-state adoption in the future. Manufacturers will use PRISM to register, prepare submissions, report PFAS in products, request waivers, and manage trade-secret claims.

Question 7

What is the Minnesota PFAS reporting deadline?

Accepted Answer

The initial Minnesota PFAS reporting deadline is July 1, 2026. This deadline applies to all in-scope products sold or distributed in the state. Beginning February 2027, manufacturers must report all new products containing intentionally added PFAS by February 1 each year. Ongoing re-reporting is not required unless a product changes, making it essential for companies to maintain a scalable, repeatable PFAS tracking process.

Question 8

What is Section 232 and why does it matter for steel, aluminum, and copper imports?

Accepted Answer

Section 232 of the U.S. Trade Expansion Act allows the president to impose tariffs if imports threaten national security. Since 2018, this has led to significant tariffs on steel and aluminum, and in 2025, copper was added. Importers must now provide detailed supply chain data (such as country of smelt, cast, melt, and pour) to avoid duties up to 200%.

Question 9

How can importers stay compliant with Section 232 reporting requirements?

Accepted Answer

Importers should:Collect mill test certificates, certificates of analysis, or supplier attestationsEngage suppliers early to ensure smelt/melt data is availableUse trade compliance software to trace metals back to the smelterWork with compliance experts to interpret CBP updates and avoid costly penalties

Question 10

What are the risks of not complying with Section 232 tariff requirements?

Accepted Answer

If importers cannot prove the country of smelt, cast, melt, or pour, U.S. CBP may assume the material originated from a restricted country (such as Russia). This can trigger a 200% duty, shipment delays, or even having goods stopped at the border. Lack of documentation creates significant financial and operational risks.

Question 11

What qualifies a product to be labeled “Made in USA”?

Accepted Answer

To make an unqualified “Made in America” claim, a product must be “all or virtually all” made in the United States. This means final assembly occurs in the U.S., and nearly all materials, parts, and processing are of domestic origin. If significant imported content is involved, companies should use a qualified claim (e.g., “Assembled in the USA with imported parts”).

Question 12

Why are “Made in America” claims facing increased enforcement?

Accepted Answer

Enforcement is increasing due to a 2026 executive order directing the FTC to prioritize action against deceptive U.S.-origin claims. Combined with existing rules that allow civil penalties, companies making unsupported claims face greater scrutiny, financial penalties, and reputational risk.

Question 13

How can companies ensure their U.S.-origin claims are compliant?

Accepted Answer

Companies should treat country of origin claims as a compliance process by collecting and validating supply chain data, documenting sourcing and manufacturing details, and aligning marketing language with evidence. Claims should be reviewed across all channels — including labels, websites, and marketplaces — to ensure consistency and accuracy.

Question 14

What changed in the 2026 EU Deforestation Regulation (EUDR) update?

Accepted Answer

The EU Council adopted revisions that postpone the application of the EU Deforestation Regulation (EUDR) while introducing simplification measures. Large and medium operators must comply by December 30, 2026, and small and micro operators have until June 2027. A new category of “downstream operator” was introduced, and certain small or micro primary operators may submit a simplified declaration instead of a full due diligence statement (DDS). These changes provide additional preparation time but do not reduce the regulation’s core due diligence and traceability requirements.

Question 15

What are companies required to do under EUDR by 2026?

Accepted Answer

Companies placing in-scope products on the EU market must demonstrate that their goods are deforestation-free as of December 31, 2020; produced in accordance with the relevant legislation of the country of production; and covered by a DDS. This requires tracing commodities to the exact geolocation of the plot of land, conducting a risk assessment, mitigating identified deforestation risks, and maintaining auditable supply chain documentation. Commodities in scope include cattle, cocoa, coffee, palm oil, rubber, soya, and wood, along with many derived products.

Question 16

What are the risks of non-compliance with EUDR?

Accepted Answer

Non-compliance penalties are determined by EU member states and may include fines of up to 4% of total annual EU turnover, confiscation of goods or revenues, temporary exclusion from public procurement, and public naming of non-compliant companies. Beyond financial penalties, the most immediate risk is loss of EU market access. Without a valid Due Diligence Statement, in-scope products cannot legally be placed on the EU market.

Question 17

How should companies use the 2026 delay strategically?

Accepted Answer

The postponement to 2026 should be viewed as a strategic preparation window, not a pause. Companies should use this time to improve supplier engagement, close data gaps in traceability, implement structured risk assessment processes, centralize supply chain data management, and evaluate EUDR compliance software. Building traceability and defensible due diligence processes now will also strengthen readiness for related EU sustainability requirements.

Question 18

What qualifies a product to be labeled “Made in USA”?

Accepted Answer

To make an unqualified “Made in America” claim, a product must be “all or virtually all” made in the United States. This means final assembly occurs in the U.S., and nearly all materials, parts, and processing are of domestic origin. If significant imported content is involved, companies should use a qualified claim (e.g., “Assembled in the USA with imported parts”).

Question 19

Why are “Made in America” claims facing increased enforcement?

Accepted Answer

Enforcement is increasing due to a 2026 executive order directing the FTC to prioritize action against deceptive U.S.-origin claims. Combined with existing rules that allow civil penalties, companies making unsupported claims face greater scrutiny, financial penalties, and reputational risk.

Question 20

How can companies ensure their U.S.-origin claims are compliant?

Accepted Answer

Companies should treat country of origin claims as a compliance process by collecting and validating supply chain data, documenting sourcing and manufacturing details, and aligning marketing language with evidence. Claims should be reviewed across all channels — including labels, websites, and marketplaces — to ensure consistency and accuracy.

Question 21

What changed in the 2026 EU Deforestation Regulation (EUDR) update?

Accepted Answer

The EU Council adopted revisions that postpone the application of the EU Deforestation Regulation (EUDR) while introducing simplification measures. Large and medium operators must comply by December 30, 2026, and small and micro operators have until June 2027. A new category of “downstream operator” was introduced, and certain small or micro primary operators may submit a simplified declaration instead of a full due diligence statement (DDS). These changes provide additional preparation time but do not reduce the regulation’s core due diligence and traceability requirements.

Question 22

What are companies required to do under EUDR by 2026?

Accepted Answer

Companies placing in-scope products on the EU market must demonstrate that their goods are deforestation-free as of December 31, 2020; produced in accordance with the relevant legislation of the country of production; and covered by a DDS. This requires tracing commodities to the exact geolocation of the plot of land, conducting a risk assessment, mitigating identified deforestation risks, and maintaining auditable supply chain documentation. Commodities in scope include cattle, cocoa, coffee, palm oil, rubber, soya, and wood, along with many derived products.

Question 23

What are the risks of non-compliance with EUDR?

Accepted Answer

Non-compliance penalties are determined by EU member states and may include fines of up to 4% of total annual EU turnover, confiscation of goods or revenues, temporary exclusion from public procurement, and public naming of non-compliant companies. Beyond financial penalties, the most immediate risk is loss of EU market access. Without a valid Due Diligence Statement, in-scope products cannot legally be placed on the EU market.

Question 24

How should companies use the 2026 delay strategically?

Accepted Answer

The postponement to 2026 should be viewed as a strategic preparation window, not a pause. Companies should use this time to improve supplier engagement, close data gaps in traceability, implement structured risk assessment processes, centralize supply chain data management, and evaluate EUDR compliance software. Building traceability and defensible due diligence processes now will also strengthen readiness for related EU sustainability requirements.

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