The Minnesota Pollution Control Agency (MPCA) is beginning the rulemaking process to implement the state’s Packaging Waste and Cost Reduction Act (PWCRA) — Minnesota’s extended producer responsibility (EPR) law for packaging and paper products. Stakeholders have only a few days left to weigh in.

Rather than releasing draft rule text, MPCA has issued an early “request for comments” (Revisor ID R-04992) asking for input on rule concepts before drafting begins. MPCA is specifically looking for input on:

• Definitions, exemptions, and the “covered materials” collection list

• Statewide collection requirements and measurement methodologies

• Producer stewardship plans and annual reporting obligations

• Other implementation topics under the anticipated new Minn. R. ch. 7035

There are many subtopics on which they are seeking specific input. The document with the detailed request for comments is here: https://www.pca.state.mn.us/sites/default/files/sw-rule3-06a.pdf

The comment period opened following the May 26, 2026 Notice of Request for Comments in the State Register and closes this Friday, July 24, 2026 at 4:30 p.m. — if you are impacted and have views on how this rule should take shape, now is the time to comment. No draft rule has been published yet; this input will inform the draft, with a formal notice of intent/proposed rule and eventual adoption to follow.

Early stakeholder input can be extra important. It creates multiple chances to emphasize key points. It can shape the first draft of the rules rather than simple reacting to what comes out. Making comments early can help those ideas come to other’s attention and can create momentum as other parties may repeat the theme. (Of course, others can differ with it as well.) Finally, it can help meet legal prerequisites that may require a level of comment in order to preserve later remedies.