Producer Responsibility Guide for Promotional Products Companies for California EPR Regulations

Guide

Producer Responsibility Guide for Promotional Products Companies for California EPR Regulations

Learn how to determine your obligations and ensure compliance in California’s evolving EPR landscape.

Fill out the form to download your Guide for Promotional Products Companies for California EPR

Are you a promotional products company manufacturing or importing unbranded products, such as mugs, pens, or apparel and customizing them with customer logos? Understanding who is responsible for packaging compliance in California can be complex.

Our Producer Responsibility Guide clarifies your obligations based on the California Association of Accountants (CAA) latest guidance released on September 23rd, 2025. This resource is designed for promo companies, distributors, and compliance officers navigating California’s EPR requirements.

Key Questions Answered in This Guide

Who is responsible under EPR when a brand owner is based in the US?

Understand obligations for primary, secondary, and tertiary packaging when brand owners operate within the United States.

What happens when there’s no US brand owner?

Learn how responsibility shifts to the first company selling or distributing products in California.

What are my EPR obligations as a promo company selling in California?

Get clear guidance on your responsibilities when customizing unbranded products and why your customer is not considered the brand holder.

How do EPR obligations differ between states?

Navigate the differences between Colorado, Oregon, and California’s specific requirements.

How can I assess my unique EPR obligations?

Discover RLG’s tailored assessment process, comprehensive reporting, and ongoing compliance support backed by 30 years of global expertise and over 58 million SKUs in our product packaging database.

Take the Next Step Toward EPR Compliance

Whether you’re just beginning to understand EPR requirements or need expert guidance to navigate multi-state obligations, RLG is here to help.

Download the full guide and gain clarity on your California EPR obligations as a promotional products company.

Disclaimer: This resource should not replace professional legal counsel—always consult qualified legal professionals for current information specific to your situation.

Would you like to learn more about RLG? Contact us here.

Les Griffith - Speakers

Business Development Director
RLGA

Les Griffith is currently the Business Development Director at RLGA and is tasked with expanding the company’s data management offerings for packaging EPR in the Americas. Les has over 30 years of industry experience in Environmental Services, Extended Producer Responsibility and Reverse Distribution. Les has spent these last 30 years working with organizations to develop progressively more sustainable solutions to the management of end-of-life materials. Prior to joining RLG, Les spent eleven years at Covanta most recently serving as the Business Development Director for the Healthcare Solutions division. His group covered North and Central America and specialized in providing a suite of services to healthcare PROs, take-back services to retail pharmacy and law enforcement and environmental services to the healthcare sector and reverse distributors. Prior to Covanta Les spent 10 years at Waste Management Inc. as an Area Manager for their Healthcare Solutions group.

Andriana Kontovrakis - Speakers

Director of Compliance Services
RLG

Andriana Kontovrakis is the Director of Compliance Services for Reverse Logistics Group’s US team.  She manages a team responsible for ensuring manufacturer and retailer customer compliance with EPR laws for electronics, batteries, packaging, household hazardous wastes, and other consumer products across the US. Along with RLG partner the Household and Commercial Products Association, she is spearheading the development of the Household Product Stewardship Alliance, a stewardship organization forming under the guidelines of Vermont’s HHW EPR law.  Prior to working with RLG, she was a Policy Analyst with the global electronics recycler Sims Lifecycle Solutions where she managed programmatic implementation and customer and supplier accounts for the US EPR compliance unit and the Deputy Director for Waste Prevention for the NYC Department of Sanitation.

Producer Responsibility Guide for Promotional Products Companies for California EPR Regulations