Private Label or Importer? Who’s the “Producer” Under EPR in the Automotive Aftermarket
As Extended Producer Responsibility (EPR) programs continue to expand across the U.S., many automotive aftermarket businesses are encountering a familiar point of uncertainty: who is actually considered the “producer” under EPR?
For companies operating as private-label brand owners, importers, distributors, or a combination of all three, the answer is not always obvious. Yet under EPR, determining producer responsibility is one of the most important steps toward compliance readiness.
Understanding how producer roles are defined — and how they apply to your business model — is essential for navigating EPR with confidence.
What “Producer” Means Under EPR
Under EPR frameworks, the term producer does not simply refer to who manufactures a product. Instead, it generally refers to the entity that places a packaged product on the market under its control.
While definitions vary by state, EPR programs typically consider factors such as:
Who owns or controls the brand
Who imports packaged products into the market
Who first makes the product available for sale within a regulated jurisdiction
This role-based approach can feel unfamiliar to automotive aftermarket businesses, particularly when manufacturing, branding, and distribution are handled by different parties.
Why This Question Is Especially Complex in the Automotive Aftermarket
The automotive aftermarket is built on layered supply chains and flexible business models. It is common for companies to operate in more than one role at the same time.
For example:
A private-label brand may source products and packaging from overseas suppliers
An importer may not own the brand but is responsible for bringing packaged goods into the U.S. market
A distributor may sell products without realizing it is considered the first entity placing them into a regulated state
Under EPR, these distinctions matter. Responsibility is often assigned to the entity with the greatest level of control or proximity to market placement, rather than to the manufacturer.
Private Label Brands: What to Consider
Private-label brand owners are frequently identified as producers under EPR because they control the brand under which products are sold.
Even when packaging design, sourcing, or manufacturing is handled by a third party, private-label brands are often responsible for:
Reporting packaging data
Registering with producer responsibility organizations (PROs)
Paying applicable EPR fees
For private-label businesses, EPR introduces new considerations around packaging visibility and supplier coordination, particularly when packaging decisions are not made internally.
Importers: Where Responsibility May Apply
Importers play a critical role in EPR frameworks, especially when products originate outside the U.S.
In many cases, if no brand owner is established or registered within the regulated market, the importer may be designated as the producer. This can apply even when the importer does not control branding or packaging design.
For importers, understanding EPR responsibility often depends on:
Whether a brand owner is registered in the applicable jurisdiction
How products are labeled and sold
Where market placement occurs
Clarifying these factors early helps importers avoid unexpected compliance obligations.
When Roles Overlap
In the automotive aftermarket, it is not uncommon for businesses to act as both private-label brand owners and importers, sometimes within the same product portfolio.
When roles overlap, producer responsibility may vary by product, brand, or market. This makes it especially important to:
Review product portfolios carefully
Understand how responsibility is assigned under each applicable EPR program
Avoid assumptions based on traditional supply chain roles
Producer responsibility is often product- and market-specific, not company-wide.
Why Clarifying Producer Status Early Matters
Uncertainty around producer status can delay compliance efforts and complicate reporting.
Businesses that clarify their role early are better positioned to:
Register correctly with PROs
Align internal teams around responsibility
Coordinate with suppliers and partners
Avoid last-minute adjustments as requirements evolve
Early understanding supports smoother compliance and more informed decision-making.
Common Questions About Producer Responsibility Under EPR
As businesses begin assessing how EPR applies to their operating model, a number of practical questions often arise. Below are answers to some of the most common questions we hear from private-label brands, importers, and distributors in the automotive aftermarket.
What does “producer” mean under EPR?
Under EPR, the producer is generally the entity responsible for placing a packaged product on the market. This determination is based on role and control, not who physically manufactures the product.
Depending on the program and jurisdiction, this may include brand owners, importers, or other entities involved in first market placement.
If we don’t manufacture the product, can we still be the producer?
Yes. Manufacturing alone does not determine producer status.
Private-label brand owners, importers, and distributors may be considered producers even if manufacturing and packaging are handled by third parties. EPR focuses on who controls the brand and who introduces the packaged product into the market.
Are private-label brands typically considered producers?
In many cases, yes.
Private-label brand owners are often designated as producers because they control the brand under which products are sold. This can apply even when packaging design and sourcing decisions are made externally.
When is an importer considered the producer?
Importers may be considered producers when:
The brand owner is not established or registered in the regulated market
The importer is the first entity placing the packaged product into the jurisdiction
EPR program rules assign responsibility to importers in the absence of a local brand owner
This is why importer status requires careful review under each applicable EPR program.
What if our company plays multiple roles?
This is common in the automotive aftermarket.
Many businesses act as private-label brand owners for some products and importers or distributors for others. Under EPR, producer responsibility may vary by product, brand, or market.
Responsibility is often product-specific, not company-wide.
Does producer responsibility differ by state?
Yes. While EPR frameworks share common principles, definitions and requirements can vary by state.
Producer status should be reviewed in the context of each applicable program to ensure accurate registration, reporting, and compliance.
What happens if producer responsibility is unclear?
Unclear producer status can delay compliance efforts and complicate reporting.
Clarifying responsibility early helps businesses:
Register correctly with producer responsibility organizations
Avoid duplicate reporting or missed obligations
Align internal teams and external partners
Prepare for future program expansion
How should businesses begin clarifying their role?
A practical starting point includes:
Reviewing product portfolios and branding arrangements
Identifying where products are placed on the market
Understanding supplier and importer relationships
Comparing business roles against current EPR definitions
This process does not require immediate perfection, but it benefits from early attention.
How can PARTSLIFE US help?
At PARTSLIFE US, we work with automotive aftermarket businesses to help interpret producer definitions and apply them practically across complex supply chains.
Our focus is on helping companies move from uncertainty to clarity so they can prepare for EPR requirements with confidence.
Moving Forward With Clarity
EPR programs are reshaping how responsibility is defined across the automotive aftermarket. For private-label brands and importers, the key question is not simply whether EPR applies, but how it applies to their specific business model.
Taking time to understand producer definitions, review operating roles, and assess product portfolios helps businesses move forward with greater confidence and control.
Understanding who is considered the producer under EPR is a critical step in preparing for what comes next.
Have questions about producer responsibility under EPR and how it applies to your business?
PARTSLIFE US is here to help guide those conversations.
Regulatory Note
This information reflects commonly available EPR guidance and industry understanding as of January 21, 2026. EPR requirements may vary by state and continue to evolve.
