VP of EPR Regulatory Compliance at Circular Action Alliance – Remote

Role Overview

The VP of EPR Regulatory Compliance will oversee Technical Advisory Services under National Program Operations Team and report to the Chief of Staff. This position will be responsible for providing regulatory, compliance and technical guidance on the development and implementation of extended producer responsibility (EPR) programs, interpreting regulatory requirements and developing policies and proposals for program plans to meet these requirements, preparing producer guidance on these requirements and maintaining the definitions for reporting categories used to characterize the various types of covered materials that producers are obligated to pay fees on under CAA’s approved program plan in each state where it is the approved PRO. The candidate will collaborate effectively across the organization and with regulatory, compliance and client entities/groups/individuals/partners external to the organization.

This position will lead the development and maintenance of reporting and fee categories and associated definitions across the states where EPR for packaging and paper products is being implemented. Technical Advisory Services provides technical support across various departments of the organization, including, but not limited, to Producer Services, Data and Analytics, and Materials Management.

The ideal candidate must combine strong operational background within the recycling and packaging design industry, as well as engagement skills to ensure successful relationships with producers, regulators, service providers and end market entities.

Key Responsibilities

1. Lead and advance the statutory and regulatory analyses of covered materials – Material and Sector Scope
   1. Product exemptions/exclusions as covered materials – interpretations, analysis and producer guidance
   2. Exemptions process for materials managed outside the common collection systems
2. Lead the development of tools to support producer compliance reviews:
   1. Conduct producer reporting reviews to ensure accuracy of reporting of covered materials included in producer Annual Reports.
   2. Develop tools to determinelikely product exemptions when reviewing producers' supply quantities.
   3. Development of procedures to identifylikely under or over reporting of supply quantities under by producer members.
3. Lead the development and maintenance of Material Reporting Categories, including definitions, examples and reporting tips, at the state level and their mapping across U.S. states.
   1. Maintain the existing state reporting categories in California, Oregon, and Colorado and mapping to the least common denominator “National” list of reporting categories.
   2. Development of Reporting Categories for new states where CAA will be the approved PRO.
   3. Responsible for the producer guidance materials and interpretive memorandums related to covered materials.
   4. Establish case histories for material definitions and document material definition changes and evolution of interpretive guidance over time.
   5. Lead national harmonization efforts to minimize administrative burden on reporting producers.
4. Advance and conduct research on covered materials and their constituent properties and attributes in the context of best practices for end-of-life management and design for recycling criteria.
5. Provide recommendations to state teams, the VP of Materials Services and the VP of Data and Analytics on end-of-life management options for the collection, sorting and recycling end markets of difficult to manage covered materials
6. Participate in forums that inform the understanding of sustainable material and packaging design and management
7. Collaborative support function for the following departments within CAA.
8. Producer Services: Interpretive guidance on material reporting to producers with respect to covered materials and statutory and regulatory exclusions. Support for consultation with producers on changes to definitions of covered materials and exclusions and exemptions and compliance reviews initiated by the department
9. Materials Services: Support development of material definitions and mapping of material categories used for compositional analysis of the collected recyclables inbound to MRFs, and outbound from MRFs to end markets.
10. Data and Analytics: Support the fee-setting process at CAA, especially in the context of design for recyclability and other material-specific eco-design criteria and differentiation through eco-modulation of fee rates.

Skills & Competencies

• Thorough knowledge of the packaging regulatory landscape beyond EPR, including but not limited to health and safety, labelling and information, transportation and handling, and trade and import/export regulations.
• Experience with statutory and regulatory interpretation and analysis.
• Excellent analytical and problem-solving skills, with the ability to interpret complex data and identify actionable insights.
• Exceptional communication and interpersonal skills, with the ability to effectively collaborate with stakeholders at all levels of the organization.
• Detail-oriented with a commitment to accuracy and compliance.
• Ability to build, develop, lead and engage strong teams, with direct or indirect reporting lines including remote employees.
• Ability to work in a dynamic environment for rapid pace and with flexibility. Ideally understand and adapt to the startup nature of CAA.

Qualifications

• Degree in law, political science or public policy.
• At least 10+ years of regulatory, compliance and analysis, or operational experience in Extended Producer Responsibility program implementation.

Compensation & Other Information

• Location: Remote
• Pay Rate: Based on a variety of factors in accordance with applicable law including the successful candidate’s relevant experience, skills, knowledge, and experience.
• Reports To: Chief of Staff

Circular Action Alliance is an equal employment opportunity employer. All qualified applicants for employment will be considered without regard to race, color, religion, sex (including pregnancy, childbirth, lactation, and related medical conditions), national origin, military or veteran status, sexual orientation, gender identity, age or any other category protected by applicable federal, state, or local law. If you require accommodation as part of the application process, please contact careers@circularaction.org listed below.