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Will Rhode Island be the 8th packaging EPR state? What the Statewide Implementation Analysis (SIA) draft shows

Will Rhode Island be the 8th packaging EPR state? What the Statewide Implementation Analysis (SIA) draft shows

Grace Lam

Seven states have packaging extended producer responsibility (EPR) laws, and Rhode Island is now weighing whether to become the eighth. On October 5, 2026, the Rhode Island Department of Environmental Management (RIDEM) released its draft Statewide Implementation Analysis (SIA), which models five ways the state could manage packaging and beverage containers. At Neta AI, our proprietary AI agent flagged the draft, and we reviewed the numbers behind each option.

Key Takeaways

  • The draft does not recommend an option, but on its own numbers, an expanded EPR program delivers the most diversion and the highest return per dollar.

  • Producers pay in every option except the status quo, with producer responsibility organization (PRO) net costs of $290 to $490 per ton collected.

  • Rhode Island's current system is underperforming, with less than half of the material collected for recycling in 2024 reaching end markets.

  • Industry has already pushed back on the model's assumptions, including its 65% recycling rate, at the November 4 public hearing.

  • Public comments close November 16, 2026, and final recommendations go to the Governor and legislative leaders by December 1, 2026.

How Rhode Island got here

In 2025, lawmakers introduced H.6207 and S.0996 as a combined EPR and beverage container deposit bill. It did not pass in that form. Instead, the General Assembly turned it into a study, which took effect June 30, 2025. The law requires a public hearing on the draft and a final report with recommendations by December 1, 2026. The consultancy RRS prepared the analysis.

A recycling system that leaks

The draft's needs assessment explains why the state is looking at options. Rhode Island disposes of about 674,000 tons of waste a year, and up to 92% of it could be recycled or composted, representing as much as $35.5 million in lost commodity value each year. Of roughly 108,000 tons collected for recycling in 2024, only about 49,000 tons were baled for end markets. 29% of what residents set out was rejected for quality, and glass sorted at the materials recovery facility (MRF) is used as daily cover at Central Landfill instead of being recycled. Central Landfill is expected to reach capacity in about 20 years.

What this means for producers: Every option beyond the status quo targets paper and packaging, which make up 45% of the waste stream.

Five options, one clear pattern

The SIA models five program plans at full implementation:

  • Status quo: today's system, funded by ratepayers and taxpayers.

  • Deposit return only: a 10-cent deposit on beverage containers.

  • EPR only: producers fund recycling of residential packaging and paper.

  • EPR plus deposit return: the original H.6207 approach.

  • Expanded EPR: adds commercial packaging, single-use plastics, packaging-like products and a 10% reuse target, drawing on Oregon and California.

Expanded EPR diverts 47% of paper and packaging, compared with 13% today, and returns $4.52 per dollar invested


In the medium scenario, diversion of paper and packaging rises from 13% today to 20% under deposit-only, 29% under EPR only, 33% under EPR plus deposit, and 47% under expanded EPR. Expanded EPR also leads on social return per dollar invested ($4.52, compared with $1.59 for deposit-only), landfill life added (5.1 years compared with 0.9) and greenhouse gas emissions avoided. Deposit-only has the smallest impact because beverage containers make up only about 10% of paper and packaging tonnage.

Producers pay in every option but the status quo

Under each program plan, producers fund the system through a PRO. Net PRO costs at full implementation are $290 per ton under deposit-only, $370 under EPR only and expanded EPR, and $490 under EPR plus deposit, the highest because the PRO funds both systems. Under every EPR option, municipal recycling costs drop from $200 per ton to $0. Under deposit-only, towns keep paying $200 per ton, and the PRO's cost covers only redeemed containers. Bottom line: if Rhode Island moves beyond the status quo, producer funding is part of every path the state modeled.

What we heard at the November 4 hearing

At RIDEM's public hearing, longtime bottle bill sponsor Rep. Carol McEntee argued that neighboring states with deposit programs are doing fine. The Consumer Brands Association questioned the study's assumptions, including a 65% recycling rate and a drop in MRF contamination from 21% to 11%. A packaging manufacturer warned costs would be passed on to customers, and Beyond Plastics backed a bottle bill but urged caution on EPR.

What producers should do now

  1. Submit comments to RIDEM before November 16 if the model's assumptions affect your categories.

  2. Map your Rhode Island paper and packaging volumes by material, since every option except the status quo bills producers by tonnage.

  3. Check whether your commercial (away-from-home) packaging and single-use plastics would fall in scope under expanded EPR.

  4. Plan on a multi-year runway. Most options begin in year 4 after a law is enacted.

What's next?

The final report is due December 1, and any legislation would come in the 2027 session. The draft already makes the trade-off clear: the broadest program diverts the most material per dollar, and producers fund it.

At Neta AI, we track changes like these in real time, across state statutes, agency rulemaking portals, PRO announcements, and local ordinances, and model what they mean for your packaging footprint and SKU portfolio. If Rhode Island is on your radar, reach out. We'd love to walk you through it.

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Stay up to date with the packaging information you need: rules, materials, cost levers and what they mean for your business. One simple email, no filler.

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Packaging intelligence, in plain language

Stay up to date with the packaging information you need: rules, materials, cost levers and what they mean for your business. One simple email, no filler.