Jeff Fielkow has experience “on every side of the recycling bin.” He’s tapping into those different perspectives as the CEO of Circular Action Alliance.

Packaging Dive caught up with Fielkow at the end of 2024 to learn more about CAA’s approach in 2025 and the years to come. As the first EPR laws for paper and packaging come into force in the United States, Fielkow says the producer responsibility organization is focused on educating and engaging producers, and working to promote harmonization in programs and reporting.

Appointed in August to lead CAA, Fielkow’s decades in and around the packaging industry include roles with Tetra Pak, WM, the U.S. Carton Council and more. Fielkow also said he has direct experience with extended producer responsibility programs in Asia.

CAA, a brand-founded, nonprofit PRO, is already working in California, Colorado and Oregon. The organization must ensure producers comply with state laws and develop a business model that aligns with long-term EPR goals, he said. It has built out its leadership team, and staffing up will continue into 2025. 

As of December, at least 2,420 producers were registered with CAA. The PRO is keen to engage across supply chain partners “so we can actually solve problems that we've all known have been there before, but there hasn't been either a forum or a mechanism to actually work collaboratively together,” Fielkow said.

Fielkow emphasized CAA’s commitment to developing state programs informed by needs assessments and “what problems you're trying to solve.” He said CAA’s team offers a blend of “fresh ideas” and experience from other markets that are no stranger to EPR.

Editor’s note: This interview has been edited for clarity and brevity.

PACKAGING DIVE: CAA is officially working in multiple states and no doubt anticipates operating in more to come. Can you share more about CAA’s approach to scaling up?

JEFF FIELKOW: We continue to build the infrastructure and the foundation for the three state programs we have [and] for potential future programs that may come online.

I would actually say that it's easier to start two or three states at once versus one state, because we can actually use the economies of scale, and we have a team of national services to support multiple states at once, which is ideal.

The first state program that will become active for paper and packaging EPR is Oregon … That’s going to start midway through 2025. We are ready. We've got a local team in Oregon and we continue to build out. A national services team has already been supporting that program. Our provider portal is on track and on time. So the very first program that goes out, we've got the scale and we've got the readiness ... I think that's a great milestone for our industry, that's a great milestone for the state of Oregon, and the team that has put a lot of hard work into putting us in that position.

How are you managing different state implementation timelines? What might the outlook be for more harmonization?

Harmonization can come in many forms. So firstly, we want to give a seamless experience to producers. You've got three big programs that are already coming online with, most likely, more to follow. We want producers to have one portal to use, one way of reporting ... and so [the producer experience] is already being harmonized.

More long term is harmonizing programs where we can across states so it’s easier for producers to understand, one, if they're obligated, to define what a producer is or is not; two, when we look at reporting commodities, to get to commodity categories as consistent as they can be from state to state.

Many programs also have what's called responsible end market validation, and harmonizing what that looks like makes it easier for the industry and for CAA to help validate ... Most of the states at this point have what’s called ecomodulation, where it rewards producers for taking actions that make their product easier to recycle or more compatible with the system, or could possibly penalize if they go the opposite direction — so working to standardize elements like that.

It is a journey. But I can tell you right out of the gates, for harmonization, simply having a single point of contact and portal to use starts to make the reporting process more harmonized for producers.

What period would you expect would be the heaviest lift for producers, and when do you think things might ease a bit?

Getting started is probably always the heaviest lift. Understanding how to report data tends to be most challenging. So I would say, from a producer's perspective, Q1 would probably be the most challenging because it's about getting their data ready for the first time in the U.S.

I will say, many producers do business outside the U.S., so this is not a new phenomenon for those that do business in multiple countries. They understand the process. Those that only do business in the U.S. that never experienced it, they'll probably have a little bit of a heavier lift in Q1, and there'll be a learning curve … and we acknowledge that.

So that's also why we do monthly producer reporting calls and meetings. That's why we have a single way for producers to ask their questions to us. There's also good third-party partners that can help with data readiness outside of our ecosystem.

What are CAA’s priorities for program implementation in 2025? How about in states where CAA is not yet officially the PRO?

When looking at the priorities, it’s very clear. It's to continue to build out our team and our infrastructure in the three states ... It's building good ways of working with standard operating principles for how we operate efficiently. 

It's also making sure that we help our state partners in Oregon [be ready.] And we're going to make sure that any interested party in that state, that we're very collaborative with.

It's also driving continued producer engagement to ensure that in 2025 we are transitioning from Oregon and getting ready for those questions that might be in Colorado.

We'll also be submitting our [plan] for Colorado in 2025. And in California we continue to work with the rules clarity to ensure that we get the program right based on the intent that was in SB 54.

And then we're also keeping the eye out on states that have already initialed and signaled that they will be implementing EPR, such as Minnesota. We're ready for that submittal as well, which is in the very beginning of 2025.

I know CAA’s purpose is on the producer management side of things, but would you expect to influence potential future EPR policies in the U.S., just based on the body of knowledge you'll have?

We have the ambition to be the ones that do the implementation. It just so happens that we have a lot of very good experience: We have great lessons learned, we have a lot of good education, so we do not mind providing fact-based education on what a good program looks like.

Those that are considering legislation, we gladly can and would share just the facts of what a good program can look like. But that's the extent of what our mandate would be.

There are plenty of people who are still skeptical about whether these programs will effectively transform a circular economy – and as managing these programs requires more overhead, where exactly producer fees will have an impact. How would you respond to those concerns?

There are good and bad EPR programs throughout the world, and so sometimes there can be a formed opinion that somebody has experienced something that wasn't good.

What does good look like? Good looks like knowing what problems you're trying to solve. So a good EPR program should be more than just shifting the cost to producers. If you really want to make meaningful change in the diversion of materials, either recycling or composting or even take-back, I cannot underscore [enough] the importance of having a high-quality needs assessment done upfront. That is a really important part when you're sequencing the beginning of the foundational development of the program. It really all begins with deeply understanding what problems you're trying to solve.

If you do that, and you build off of that as a foundation, I'm highly confident that EPR will be successful in states. It'll engage producers, but will actually be able to make a change. And a change means we want to see more diversion, we want to see better responsible markets, we want to see a higher consistent quality of education and outreach to engage citizens — and that all really happens with high-quality needs assessment.