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Compliance Certification Reporting for New Jersey’s Recycled Content Law

[/vc_column_text][/vc_column][/vc_row][vc_row][vc_column][vc_column_text css_animation=”none” css=””]Manufacturers of containers and packaging products that are subject to New Jersey’s Recycled Content Law are required to certify compliance with the law’s postconsumer recycled content requirements on an annual basis beginning in 2025. Compliance certification reports are required when regulated containers and packaging products were sold or offered for sale during the prior calendar year.

To streamline submissions for manufacturers, the compliance certification reporting process has been integrated into the registration process. Manufacturers will submit their annual compliance certification report when they submit their registration through the NJDEP’s online registration services, which are open for submissions from September 1 to December 31 each year. However, please note that in 2025, Labor Day falls on September 1, so NJDEP’s online registration services will open on September 2.

For 2025, the NJDEP has developed a compliance reporting form spreadsheet, available below. Manufacturers are required to complete the spreadsheet and upload it as an attachment to their registration. Manufacturers will not be able to register without uploading the compliance spreadsheet.

Although the manufacturer’s registration and compliance certification report must be submitted together, the registration must list the containers and packaging products that were sold or offered for sale in New Jersey during the current calendar year while the annual compliance report must provide the manufacturer’s compliance data from the previous calendar year. As such, manufacturers are essentially certifying that the containers and packaging products listed on the prior year’s registration were in compliance with the postconsumer recycled content requirements. Please note that a compliance certification report is still required if the manufacturer failed to register for the previous calendar year unless:

• The manufacturer did not register because they did not sell or offer for sale any regulated containers or packaging products in New Jersey during that year.
• The manufacturer is not required to submit an annual renewal registration because they generate only exempt containers and packaging products.

Manufacturers will need to indicate whether their compliance data is based on state-specific or national data. If using national data, the manufacturer will need to prorate recycled content data to New Jersey, based on market share or population. The manufacturer will also need to thoroughly explain their calculation methodology and provide documentation demonstrating that state-specific data is not feasible to generate. To assist with this, the NJDEP has developed guidance for prorating national recycled content data to New Jersey that also includes examples for how to explain the calculation methodology.

Annual Registration and Compliance Reporting Period:

Reporting Timeline Breakdown:

2024 (before compliance reporting is required)

Jan – Aug: Registration closed until September

Sep – Dec: Manufacturer registers regulated containers and packaging products for current calendar year

2025

Jan – Aug: Registration closed until September

Sep – Dec: Manufacturer registers regulated containers and packaging products for current calendar year AND submits compliance report for products from 2024

2026

Jan – Aug: Registration closed until September

Sep – Dec: Manufacturer registers regulated containers and packaging products for current calendar year AND submit compliance report for products from 2025[/vc_column_text][/vc_column][/vc_row][vc_row][vc_column width=”1/2″][info-box-shortcode icon=”fa fa-solid fa-file-excel” title=”Recycled Content Manufacturer Compliance Reporting Form Spreadsheet” buttontitle=”Download” buttonlink=”https://deptest.nj.gov/dshw/wp-content/uploads/sites/133/recycled-content/recycled_content-2024-compliance-certification-report-form.xlsx” targetlink=”true”]Last Update: May 20,2025[/info-box-shortcode][/vc_column][vc_column width=”1/2″][info-box-shortcode icon=”fa fa-solid fa-circle-question” title=”Guidance on Prorating National Data and Explaining Calculation Methodology” buttontitle=”Read more” buttonlink=”https://deptest.nj.gov/dshw/wp-content/uploads/sites/133/recycled-content/recycled_content_prorated-calculation-guidance.pdf” targetlink=”true”]Latest Update: May 20, 2025[/info-box-shortcode][/vc_column][/vc_row][vc_row][vc_column][vc_empty_space][vc_column_text css=””]If assistance is needed at any point, please contact NJDEP – Division of Sustainable Waste Management at recycledcontent@deptest.nj.gov.[/vc_column_text][vc_empty_space][/vc_column][/vc_row]