Extended Producer Responsibility (EPR) in Beauty: What you need to know

0:10Dr Akemi Ooka: Welcome to the EcoWell podcast. This is a show about the science of cosmetics. My name's Jen and I'll be your host. So far this season, I've been on a kick with roundtable discussions. This podcast features yet another one on the topic of extended producer responsibility, EPR, coming at it from the point of view of general EPR consultant, Dr. Michael Washburn, and the beauty industry specific viewpoint of Dr. Hakemi Oka, who is the CEO of the Trade Association Independent Beauty Association, who's been doing a lot of work on the EPR front. between educating its members about their obligations, but also helping legislators and regulators understand the beauty-specific context, which, as you'll hear in this convo, it shouldn't be a given that regulators will be in the know about the intricacies of beauty packaging, quality control, and supply chains, or the federal rules that govern beauty.

1:07Dr Akemi Ooka: EPR is an increasingly important topic for beauty around the world. If you are a beauty brand and haven't started thinking about EPR yet, trust me, you need to change that now. The intention of this podcast episode is to give you a decent diving board so that you can take the right steps you need to to stay in compliance. Because the potential repercussions of not doing so, they can literally break your business. Just a quick example, certain states currently have fines related to noncompliance up to$50 ,000 per day since the law was implemented. I don't think not keeping up with the rules is going to get you out of hot water if you end up in it.

1:51Dr Akemi Ooka: Now that I've got your attention, hopefully. Before the episode, thank you so much to my Patreon supporters for supporting my SciComm work, including this podcast. You've been a big part of my motivation that's kept this show on the air for so long. Thank you so much for your continued support. If you'd like to support my Oyercom Patreon and it's accessible, you can find me at patreon.com slash the ecoo. Other great ways to support this podcast is by subscribing to it on whatever platform you listen to it on, writing a review for the podcast if you haven't already, and sharing. And with that, here's the episode.

2:29Dr Akemi Ooka: this conversation is going to be about epr featuring two relevant subject matter experts from the straight epr i would say perspective we've got dr michael washburns from the beauty specific perspective we've got dr akemi oka collectively doing really great work in their respective spaces. Michael does consulting and education around EPR. You have the EPR Academy, a really great resource. Is that what it's called? I got that right. For brands or whoever wants to learn more. And Akemi is now the CEO of the Independent Beauty Association. Okay, I'm going to get right to it. So my first question, because I feel like a lot of people who have entered this conversation are like, what are you talking about?

3:21So for Groundwork, what is EPR?

3:26Dr Akemi Ooka: And then what is the history of it? And how has that landscape changed? And I realized this question just became a lot bigger, but I'll start this with you, Michael. Would you like to start?

3:38Dr Michael Washburn: Sure. I'm happy to. So an abbreviated history of EPR. So EPR first came into play in Europe in the late 90s and has now been adopted in at least 50 countries around the world, including the United States. It's a policy tool that takes the way that we typically handle paying for solid waste. It takes the burden off of the public sector, off of taxpayers, and places it on the companies that place material on the market. So as it relates to packaging, and I'll be specific to the United States. We have seven states now where companies that make and sell packaged goods, so a lot of our beauty brand friends out there, are responsible to report to these states how much packaging they sell into those markets every year and pay fees for the recycling of that packaging.

4:34Dr Michael Washburn: And those states for the uninitiated are California, Colorado, Maine, Maryland, Minnesota, Oregon, and Washington. So seven states total, more to come. And the programs began, Oregon's began in March of 2025. So if this is news to you, and you are an obligated producer because you sell in those markets and have obligations, then you have some reporting to do.

5:07Dr Akemi Ooka: And I guess to Akemi, same question, except as it relates to beauty. So I think the distinction for beauty with respect to packaging EPR is the requirements around this sort of framework is that you as a producer, an obligated producer, which for beauty often means the brand, because they're making decisions about the packaging, is required to report the type and tonnage of material that you're using and distributing and selling in these states. For beauty, that can be very complicated because beauty packaging is some of the most complex packaging, I think, in the consumer goods sector. So when you think about the range of packaging types and beauty that would need to be delineated in sort of data reports.

6:06Dr Akemi Ooka: It includes anything from, you know, a simple jar with a closure to a really complicated pump, right? That, you know, a container with a pump and the pump itself might have 15 different parts to it. And each one of those components need to be understood in order to be able to report properly and effectively, right? And understand across your product portfolio. You may also have aerosol products that are bag and valve. You may have glass products. You may have packaging. All of it really does need to be understood and outlined so that you can properly report the packaging across the entire product line that you're selling into any of these given jurisdictions.

6:56And so I think for the beauty industry, it can be a really daunting task, right?

7:01Dr Akemi Ooka: Because, you know, your product line may have a number of different packaging types and components in it. There also are other requirements, depending on the state that has issued and passed the law to incentivize more circularity within the sort of value stream for packaging. And those can also be really, really difficult for beauty companies to meet. So requirements for things like source reduction or reuse and refill, you know, even the definitions sometimes of recyclability or compostability can be really difficult because they do sort of change depending in the jurisdiction. And so your packaging may not meet all of those requirements in all those states.

7:50Dr Akemi Ooka: So I think for beauty in particular, it's a pretty fraught landscape.

7:54Dr Michael Washburn: Hey, Jen, just real quick, now that we've freaked out your listeners sufficiently.

8:00Dr Akemi Ooka: I feel like we could freak them out more by letting them know about the fines.

8:04Dr Michael Washburn: Oh, there's more. Yeah, there's more freak out to come. But let me see if I can dial it down at least a little for folks in this sort of indie brand community, right? So in California, if you have under a million dollars of sales within California, then you need only register with CalRecycle, but you do not need to report or pay fees. So that's a considerable number of companies. And then in the other states, this does require some analysis, but if you sell less than one metric ton, which if memory serves is about 2 ,200 or so English pounds of material in that state in a year, again, you would be exempt.

8:48Dr Michael Washburn: So it's super important to understand the nuances of each state and make sure you review the exemption criteria because there will be some, yeah.

8:58Dr Akemi Ooka: And not to burst Michael's bubble in trying to like ameliorate the concerns of the beauty industry, it doesn't take much to get to a million dollars in sales in beauty because the price points tend to be higher, right? And because the value of the components or the ingredients, you know, drive just like a higher price point in the market. So you can still be a relatively small company and still have a million dollars in sales. So, but I think his point about really understanding those thresholds per region or per jurisdiction is really, really important so that you understand what your obligations are and, you know, what you need to do kind of in those regions.

9:46And also, you know, for beauty,

9:48Dr Akemi Ooka: I think like this category has a lot of virality to it, like social virality. So you could be under a million, you know, one day, and then your product is viral and you're over a million, the next day. So I think that's the other thing that's maybe to some degree more unique in beauty than other industries is just that ability to kind of drive sales quickly, even if the founder or the brand had no intention for it, something an influencer says or some usage that was sort of unexpected can just suddenly drive a product past these thresholds. So it's something that they should really understand and understand like what happens if you do, if you do pass.

10:33Dr Akemi Ooka: And so what are your obligations?

10:35Dr Michael Washburn: For sure.

10:35Dr Akemi Ooka: I guess my next question, just to kind of zoom out a bit, does or can EPR work? And I guess like work, like what do we mean by that? What's the benefit of EPR? Are there case studies to demonstrate a benefit? And then on the flip side, what are some of the challenges that may make those beneficial outcomes less likely? Are there any examples? Like just right now, I'm thinking about some of the conversations about refills as potentially getting in the way of certain benefits. But y 'all stop talking, but like reinstate my question. Can EPR work? And could you give us some examples? And then the flip side.

11:38Dr Akemi Ooka: Michael, do you want to start?

11:40Dr Michael Washburn: Yeah, there are examples. If you look at the programs in Europe or Southeast Asia, There are metrics that show, for example, the Belgian program, if memory serves, a doubling of recycling rates from the beginning of the program. We're looking to see if we can get those kinds of results here in the United States. You know, the laws actually require industry to meet certain recycling targets. So that's the point of this is to dramatically improve and increase recycling across the board, divert material from landfills, create local economic development. There's a whole host of benefits that flow from it, not the least of which ultimately is a reduction in emissions associated with the sourcing of original packaging, because we know from lifecycle tools that recycling of materials in most instances is a less energy intensive process versus creating the material in the first place.

12:38Dr Michael Washburn: In terms of obstacles, Jen, you know, the single biggest obstacle right now for these programs is getting consumers to participate. And if you think about what's wrong with recycling in the first place, it's confusing. It varies from place to place. People look at a package. They don't know if they're supposed to recycle it or not. EPR creates a financing mechanism that gives communities the ability to message to consumers and help clarify that. States can unify what's accepted across jurisdictions. Those are things that you just can't do the way recycling is organized right now. Within the program, hopefully, is a solution to some of the obstacles.

13:24Dr Michael Washburn: I'll let Akemi speak to refillables if she wishes. I'll just say that moving to a refillable package is one of the options for reducing a company's individual cost burden under EPR. It's also part of the goals that are embedded in SB 54 in California. So industry is looking at ways to do it. I think for cosmetics, personal care products, obviously, that's a really complex space when you get around the safety and integrity and cleanliness of packaging. But Kemi, do you want to speak to other obstacles? Yeah, no, I think that's definitely a good summary.

14:04Dr Akemi Ooka: I mean, I would say that, you know, I think that EPR, it actually exists in other categories, you know, paint, batteries, mattresses. I think that in some ways EPR is very effective when it's very narrowly scoped because the messaging is tighter, the audience is more focused and more targeted. I think what makes these sets of laws really challenging is the breadth of the products covered by these laws. So you're not only talking about mattresses, you're talking about all products that use packaging, you're talking about food service, you're talking about, you know, anywhere from like cosmetics to household to, I don't know, maybe pet, like institutional, as well as food service and food and beverage.

14:53Dr Akemi Ooka: It's just a really broad, broad group of products that are affected. So the messaging, I think, around it to Michael's point about consumer awareness is actually kind of challenging because you don't have just one target. You're trying to talk about this to all of these different people. And then the kinds of materials that you're talking about may or may not have really different recycling instructions if they're recyclable at all. Right. So the breadth of what's covered itself, just that alone presents a number of challenges. You know, having been in procurement, I think one of the outcomes is trying to drive a circular economy where you're sort of creating a secondary market for the recycling materials to be used.

15:39Dr Akemi Ooka: And that's also really challenging because you're you're trying to create the secondary market. But again, like who is using it? This is like this huge swath of where these sort of recycled resins and materials could be used. So what are the specifications or what are the material properties or the mechanical, physical chemical, mechanical properties that need to be in that reclaimed material or recovered material or reusable material? And what are the industry applications for those, right? So you're trying to sort of create a secondary market to create and drive demand, but it's unclear sort of like where's the right home for that demand or the right pilot place for that demand to kind of be tested out.

16:26Dr Akemi Ooka: Right. So I think that that makes it really difficult, too, because you're sort of like, I don't know where the biggest opportunity is. And then I think for beauty in particular, they're just like these challenges with either conflicts, contradictions or difficulty and ever finding a way to synergize like the other laws that are already governing the category. So when you think about things like labeling, like very fundamental, like, you know, beauty products need to have descriptions on their label of the product. They need to have lot codes. They need potentially expiration dates, right? Like they're just depending on the kind of product it is.

17:05Dr Akemi Ooka: You may have for any given, you can have a body wash, but you have five different fragrances of that body wash. Producers are required to tell consumers what is in the package. And so they're required to inform consumers on the label of the ingredients and what's in the package. If you start to get to reuse or refill models that Michael mentioned, you do get into these challenges around how do you practically implement that so that you know that the label on the product that has been reused or refilled is accurately describing what is inside the product. If you are not, then you're in violation of FDNA labeling requirements, right?

17:48Dr Akemi Ooka: Like, so do you have the right lock code? Do you have the right fragrance? Do you have the right ingredient disclosures on the product? And the reason you want that is because if someone has an allergy or someone has a reaction or the product goes bad or something, like you can go back and you can accurately and confidently say it was this product, this lock code, this fragrance, this color, whatever it is, and you as a consumer or a physician or whoever, you know, retailer is reporting back like something went wrong with the product. And with the latest modernization of Cosmetics Regulation Act of like with MoCRA, you're required to report back any adverse events associated with, you know, with the product.

18:31Dr Akemi Ooka: And so I think reuse and refill is like, is really challenging as just a format because Because I think it's not clear exactly how you would ensure that in this case, just this alone, like that labeling is correct on the package. And we've seen some groups try to do cartridges and refillable cartridges. And some of the concern with that, I think, is the question comes up, like, are you really reducing packaging in that instance, though? Like, are you actually creating more packaging or it's still single use packaging? So I think there's a lot of work and people trying to innovate in this space to figure out like, how could you actually do this and still really comply with requirements, not just in California, but like anywhere else, right, where that is incentivizing reuse and refill.

19:18Dr Akemi Ooka: The other things are just are really they're sort of obscure, but they really, I think, are part of the challenge. Things like the MOCRA regulations, you know, require manufacturers of cosmetic products to be listed with the FDA and you have to follow guidelines around good manufacturing processes and practices. And like if you are a refill center, refill station, if you put that into your local mass store and a consumer goes to that store, whether it's supermarket or convenience store, they go to a big box store and then refill the product that technically becomes a manufacturing site. Right.

19:59Dr Akemi Ooka: So then do they now have to follow all of these other required procedures? And so all out of that are like huge question marks. And so that's really challenging. I think maybe for the, I don't know about the other industries, but like for the beauty industry, I think those are really challenging. And so when you think about incentives, it's sort of difficult, I think, for the beauty industry to try to take advantage of those incentives because they're just these other considerations that make it, I think, difficult to implement. And I feel like this brings up challenges in terms of evaluating the potential beneficial outcomes of VPR.

20:36Dr Akemi Ooka: So with, for example, with refill cartridge products, they require a certain amount of uses from the consumer to then have a improved environmental outcome for the product. If people don't like the product and often they're more expensive, like if the consumer demand isn't there, then are they actually improving things? There was another study this past year, or maybe it was the year before. A group of researchers went around to hotels to evaluate the microbes in, I don't know if you saw this, in hotel shampoo dispensers. The refiller ones wasn't good. There was lots of microbes built up. And so the potential public harm, all this is to say it's a really messy space.

21:33Dr Akemi Ooka: It's confusing. Good information is really important. However, I mean, that's hard. There's so many stakeholders to consider. I'm just going to go on to my next question. And I'm going to put a disclaimer before I ask the question, which I meant to say up front, but I forgot. We are recording right now on June 17th. I record my podcast really early for my season. So the situation might look a little different by the time you listen to it, but a lot of what we're talking about will still be the same, maybe minor differences. So the question, what does the current picture and future of EPR look like?

22:17Dr Michael Washburn: Well, where to start? So here we are on June 17th, June 1st of this year. So two and a half weeks ago was this year's deadline for reporting in the United States in six of the seven states, It's all the states except for the state of Maine. So for companies, again, to whom this is news, not only if you're an obligated producer, might you owe reports for this year reporting on your data from 2025, but you may also have reports due for last year, which you'll be required to do when you register with the Circular Action Alliance. quickly just to explain the circular action alliance individual companies are not you know required to set up recycling programs across the state of california or the state of oregon that's done through an industry organization called circular action alliance or caa it's an independent non-profit it's governed by producers so large brands sit on its board and some smaller brands.

23:25Dr Michael Washburn: And so CAA is the entity through which thousands of companies comply into the respective states. In addition to the supply reports that are due, now that the state of California has finalized its regulations under SB 54, there's also what's called the 2023 interim report, or sometimes called the baseline report, where for California, those companies that are obligated have to document how much plastic, well, how much material across the board, all materials, was being sold in 2023 in California. And special emphasis is placed on plastic, including the total weight of plastic and the total number of components.

24:10Dr Michael Washburn: So when Akemi was speaking a few minutes ago about a pump within a bottle, those are deemed separable. You have to report the pump in a category. You have to report the bottle in a category. You have to be alert to the material types that dominate those two components. There's some complexity to it. That baseline is super important because California requires us by 2032 to have eliminated 25 % of plastic packaging, both by weight and by total number of components of plastic sold in California. So again, if there was 100 units being sold in 2023, when we get to 2032, that number has to be down to at least or at most 75.

25:01Dr Michael Washburn: That is a considerable requirement under an EPR program. It doesn't exist anywhere else in the world that aggressively. So that's the situation now. And most producers who are engaged in this have figured out how to do the reports. They're figuring out now how to meet those source reduction targets. It's a complex exercise. In terms of what's coming, I mentioned that the state of Maine did not require reporting yet. That is because Maine hasn't selected its stewardship organization. That may ultimately be Circular Action Alliance, but as of June 17th, it was just this week that the state of Maine issued an RFP looking for qualified stewardship organizations to apply to run the Maine program.

25:47Dr Michael Washburn: CAA will certainly apply, may or may not be chosen. It could be another organization, and then we'll have a different stewardship organization through which to report for Maine. So there are some things that are dynamic over the course of 2026. You can check the Circular Action Alliance website for updates. There will certainly be ample news coverage, it won't be hard to figure out the status of that. And then the last thing I'll say as we look forward into 2027, I think we'll see passage of a law in Illinois. In 2026, we saw consideration of EPR in a number of states, Rhode Island, as has been true for years, New York, as has been true for the last several years, New Jersey, but there were no new laws passed in 2026, but there will be more states in the future.

26:39Dr Michael Washburn: And just quickly, for those who may sell in Canada, all the provinces have active programs. So again, you should check your obligations there. And when you get out into the EU, Asia Pacific, Latin America, it's quite a frontier. There's a lot of variation in the programs and a lot to explore. So if you sell globally, you really want to make sure that you're up to date on what those requirements are. They're changing in Europe right now. So just a lot to track.

27:06Dr Akemi Ooka: Michael covered it really well. I think the thing that is more when you think about, I mean, I think he covered sort of what's happening this year. I think that the thing to cover when you look to the future is just that this is a framework that this, at least in the US, the states have really embraced. And it's because that the way the law works is to really drive the cost, the sort of paying for collection, treatment, recycling, infrastructure for packaging. It's like, it's really driving that to be borne by the producers instead of by the taxpayers in a specific area. So I think that to Michael's point, I think that there are just like a lot of state governments that are really looking at these kinds of bills, these EPR bills.

27:57Dr Akemi Ooka: And it's not just progressive states that have strong sustainability programs or something. I mean, even Tennessee put forth an EPR bill, so it's because as states are looking for where are they going to get money to pay for programs in these municipal services, and in particular, recycling infrastructure, where are they going to go to get it. And so I think that we're likely to continue to see this emerge in the US at the state level and not just in very progressive areas. I think that it has a fairly broad appeal as a framework across all kinds of states. So I think we're going to just continue to see that develop.

28:42Dr Akemi Ooka: I don't know if we will really get much better about explaining this to the consumer, But I think as the actual cost of the fees are starting to roll out as well, and companies are starting to have to pay the fees. And I think as you think about like multiple states where maybe fees have to be paid, that that is starting to affect overall margin for products, right? And there's a certain amount that I think producers can absorb. Again, as you have more and more of these, it's just a compounding fee state by state by state. And so what I don't know is if that is going to start showing up in pricing, in the cost of goods on the shelf.

29:28Dr Akemi Ooka: So I don't know how much we're seeing that. There's a lot of other things that are really affecting the cost structure of products today, whether it's tariffs or the supply chain or the price of oil that's sort of driving a lot of things up. But I think this is another one that as producers start to understand what that cost implication is. And it's not just the hard cost of the fees. There's investments that you may need to make in reporting or in people or in systems or whatever it is to kind of keep track of the information. You could start seeing that show up as well. So do I think it'll be the next year?

30:02Dr Akemi Ooka: I don't know, but I think that that's something else to watch. The patchwork of rules in the States is, I mean, it stresses me out for brands that are entering the space. There's a lot to contend with. I'm just wondering, are there examples of success for EPR that's been rolled out from like a national perspective rather than in small regions? What would be, I feel like we can all think about, but what would be some of the challenges of this happening at a federal level in the, for example, the United States? I understand that the infrastructure varies depending on the region. Obviously, that would be one issue.

30:53Dr Akemi Ooka: But then on the flip side, it's like the burden of compliance for brands. It's like, honestly, it's so stressful to even think about it. I don't have a brand. I would say if people feel like having the federal government set a framework is inherently

31:11Dr Michael Washburn: going to simplify things, I would ask for them to show me the example of where that's proven true. In terms of the obstacles for it, folks may have noticed that the current Congress and administration haven't been wildly productive on thoughtful public interest-related endeavors in recent years. It is also true that to the extent that we still have traditional political parties in this country, both Republicans and Democrats historically have been somewhat reluctant to preempt states with federal legislation. There are examples of that, but I think for states like the seven or maybe more who already have programs in place, it's likely that they would not be affected by a federal program, but rather all the other states that don't have such programs might have some unifying system applied to them.

32:15Dr Michael Washburn: And then the final thing I would say is, to your point, Jen, about varying costs, even if you had a sort of unified program that would apply the same in Idaho as it might in Alabama, the cost to administer and run recycling programs in different places is wildly varied. And so there would still be some complexity around the setting of fees, how fees would ultimately be allocated. And I think that that complexity itself is likely a barrier to seeing this at a federal level. It's a terribly complex endeavor, no matter how you do it. And in some ways, it makes much more sense to do it at a more local level, in this case, being at a state level.

33:02I think for brands, I also kind of get stressed out when I think about the

33:09Dr Akemi Ooka: implications for brands and businesses in the space. I do think that there's value in trying to get some more harmonization across the board, right? Like definitional harmonization and standards. Like there's something I think that that would be very helpful if we, because honestly, like the cat's out of the back, like the toothpaste is out of the tube, right? Like, so you can't like push it all back in. Like there are already seven states that have enacted this, But trying to drive more harmonization there and then going forward, I think could be very, very helpful for brands. Because what happens is like each state has slightly different rules.

33:44Dr Akemi Ooka: And you start to get to this place where you're like, am I going to have to actually have 50 states and 50 different formulas and products? Like, you can't do that. And as a brand and a company making any product, that is just not a formula for success, right? So I think there's got to be some level of harmonization that allows brands to be able to make product that can be sold across the U.S. and not have so many of these unique requirements, like state by state, right? Because especially for like, you know, small brands, you know, like the ones in our membership, you very quickly get just to a decision that's not about whether you want to comply or not.

34:30Dr Akemi Ooka: It's whether you can comply or not and whether you can afford. And then your choice becomes like, well, do I just not comply and take a risk and see what happens? Or do I just have to like pull out of the state and not sell in the state? which then means you've got this weird situation where like, I can buy something in Nevada, but I can't buy it in California, or I can buy it in this, which currently with the, maybe years ago, that was not so crazy a model because you had to go drive to a store to buy stuff. But now with e-commerce, it's like super complex because the way people buy is not defined by the state border.

35:12Dr Akemi Ooka: And even the way retailers fulfill is not necessarily defined by the state border. And so really, you want to try to have as much consistency as possible so that you're not running into these issues that are sort of defined by states when the way the kind of ecosystem works isn't really defined that way. And I think that Michael's point about what makes is also really difficult is that the waste management and collection is just not federalized. It's so specific to the region you're in. Whether and how people collect waste in a really rural area is very different from how they would collect it in a super dense urban area.

35:58Dr Akemi Ooka: And the tax base and the infrastructure and the space and the environmental regulations, all that is really different in each of these jurisdictions. And so that also makes it really, really challenging from a collection and waste management standpoint. And then even from like a messaging standpoint, as I mentioned earlier, right? Because like, you just have like different infrastructure in different locations. But I think we would like to see a lot more harmonization. I think at least that would help to not have to have like 50 different products or 50 different states.

36:37Dr Michael Washburn: You mean you think we should say that there's the same array of packaging in Colorado that there is in Minnesota and not have different lists? Makes way too much sense. Yeah, that would be a great start, right?

36:52Dr Akemi Ooka: Like the list, the cover product list would be great. Yeah. Goodness. My next question, I'm going to direct this to Michael. what are some of the penalties for getting this stuff wrong and i feel like the terror number that avril love from k and l gates gave me it was like fifty thousand dollars per day since implementation of the law is that correct did i get that is that is for california so yes that's

37:25Dr Michael Washburn: correct so let's talk about what compliance looks like so to be compliant if you're obligated. So again, am I under the threshold or not? Do I sell materials that are obligated under the program or not? If the answer is yes to those things, then you're an obligated producer and you need to comply. And to be clear, I talked to a company yesterday who's still asking the question, do we really need to do this? Well, do you need to abide by the speed limit? Do you need to pay your taxes? I'll let rational people answer that question for themselves. It's a law. There's a compliance requirement. There's compliance risk.

38:09Dr Michael Washburn: So non-compliance looks like this. You don't register and you're an obligated producer, you're out of compliance. You register but don't report, you're out of compliance. You register, report, and don't pay your fees on time, you're out of compliance. And I've seen people in all of those categories. So it's already happening for Oregon and Colorado. We see companies who are in receipt of one or two delinquency notices. The delinquency notices say we, Circular Action Alliance, and we, for example, Colorado Department of Health and the Environment or Oregon Department of environment quality are putting you on notice that you are out of compliance and you have a certain period of time to respond depending on the notice.

38:59Dr Michael Washburn: It might be 30 days, might be 90 days. After that, and we're not there yet in time, we might be there by the time this airs, the respective state authorities have jurisdiction given to them by the respective statutes to enforce compliance. And that can be the application of fines. In Oregon, the fine is$25 ,000 a day for being out of compliance. Those fines tag back to March 31st of 2025. The last time I ran the number was a couple weeks ago. That's north of$9 million now. And if you should be out of compliance for some number of years, let's say you don't get discovered until 2027, 2028, whatever, the law requires you not only to pay the fines that the department might levy against you, but you still have to register, report, pay your fees back to the beginning of the program.

40:05Dr Michael Washburn: So all the years going back to, again, in Oregon, March 31st. Last year, Colorado, July 31st last year, all the way up to that current date, plus interest and late fees. So the compliance risk is considerable. Now, I'll just say this, and then I'll be quiet. There are a couple thousand companies today who are complying with all of these states. Those companies are ultimately paying the program fees for everybody. In California, we don't have final numbers yet. I'm going to guess that between 2 ,000 and 3 ,000 companies have registered and reported for California. That's probably less than 10 % or around 10 % of the number of companies who are obligated in California.

41:04Dr Michael Washburn: Nobody knows that number, but I've seen data that suggests it could be about 20 ,000 companies. It isn't fair that those who are doing the right thing are paying the freight for those who are sitting on the sidelines. So there's a shared incentive for those companies to look at the registration lists, call out their competitors and tell CAA or CalRecycle or whoever, hey, I think this company should be registered and reporting. And then you're going to receive one of those notices that I described before. So my advice is take it seriously. It is real. Closest analog we have to it is the Washington state PCR post-consumer recycled content law, which has been in effect for a few years.

41:44Dr Michael Washburn: We saw Washington Ecology last year issue fines to a host of companies who are out of compliance with that state regulation. So that is some evidence that states are going to be taking this seriously. That was a long answer to a short question.

42:01Dr Akemi Ooka: Well, and Jen, I'm going to just add to that a little bit that I think this idea of like kind of the call out by your peers or call out by your competitors is real. Many of these lists are public. So CAA does make lists of who is actually registered, you know, in a given state. You could have your competitors checking to see, are you registered? And if you're not, I'm going to send a little note to the authorities over that area and say, you should really check on this company. So I think that that kind of peer call out is something companies should be thinking about. The other thing is that even if the agencies are really focused much more on compliance, you know, we just had like a big conference this May, our cosmetics convergence conference, where the focus was to meet the regulators.

42:53Dr Akemi Ooka: And we invited regulators from Cal Recycle and from Colorado DPHE and even from Vermont. And, you know, in many ways, they're like, look, we're not trying to go and like go after people. We're trying to enact this law that was put in place by legislators, policymakers. And so their first, I think, instinct isn't to try to go and find people. They're really trying to drive compliance first and foremost. But it doesn't stop the plaintiff's bar. It doesn't stop lawsuits from happening that are filed by other parties. And these are like very, very widespread in the cosmetics industry and personal care industry.

43:35There's just like a lot of lawsuits.

43:39Dr Akemi Ooka: And they would be born out of sort of more obscure text around like whether or not you are fully in compliance with all, you know, laws, you know, all applicable laws. And whether you are claiming to do that and deceiving consumers or customers or whatever it is. And so I think brands and businesses should be thinking kind of really broadly about penalties and not just the penalties that would be levied by the regulatory bodies or the attorney general's office, but these other places that could cost you. Even social media publicity could have a cost and an impact to a company's bottom line. So I think you have to think really broadly about when you think about penalties, there's, yeah, the actual fines.

44:30Dr Akemi Ooka: And they may or may not be levied, but there's just other stuff that also kind of comes along for the ride. yeah I feel like the the amount of people that I have talked to with brands that I say EPR I'm like what's that it's like it honestly like it gives me a little bit of chest pressure of anxiety thinking about the stress associated with it like you should know you should know about this the other thing that I will say is what Akemi was just talking about maybe a surprise maybe I don't know, to some of my listeners where they feel like there's not that much risk for noncompliance in the States.

45:13Dr Akemi Ooka: But then I think about, yeah, the consumer lawyers. For me, if I had a brand, I don't think I'd want to sell in the States personally. I don't think I'd want to go there because of the risks associated with lawsuits that even if you don't do something wrong, you can get a lawsuit against you. I'm going to go to my next question. How is this all impacting beauty businesses? And how does this vary from company to company, region to region? I'll direct this day, Kemi. The beauty companies that are aware of these laws and regulations are taking steps, right, to be compliant. So they're doing all the steps.

45:55Dr Akemi Ooka: They're registering, they're reporting, they're paying fees, they're investing in the infrastructure that they need to do this properly, right? And when we talk to brands, we're like, you have to be prepared to ensure that your whole organization understands what this requires, because there's a top to bottom, and a kind of across sort of left to right, like across your organization, you because there's a financial component to this, like you're all the way to the top, like your company needs to understand like what the financial implications are of both compliance and non-compliance. And then across the companies, you really have to make sure that functionally and cross-functionally, you are coordinating with everybody because your labeling needs to be right.

46:42Dr Akemi Ooka: Your procurement needs to be right. You need to be thinking about innovation and what's coming in the future. You need to be thinking about if you need to do source reduction. It's not siloed within one director of sustainability or one packaging procurement person. This is really something that I think the companies need to know top to bottom and across the board. And so I think for those companies that are doing the right things, they are making sure that their leadership and their cross-functional teams are fully aware. The concerning impact, I think, could be going forward where you really do start to see the impact of fees and or non-compliance penalties or even maybe these lawsuits emerging in the industry.

47:32Dr Akemi Ooka: What is that really going to look like? I think that's kind of a question. I don't know. I think there's still not a lot of, I don't want to say not a lot of impact, but it's because of your point earlier that people just don't know what it is. So the current impact right now is that there's so many brands and businesses that just don't even know about, they're not really doing anything. They just don't know. And not because they wouldn't want to if they did know, they just don't know. I think there hasn't been a very strong and successful campaign to get people to know. IBA's definitely been talking about this.

48:09Dr Akemi Ooka: I've been talking about this for four or five years, but we're just one voice. And again, these are sweeping laws across multiple consumer goods sectors. And it's always surprising to me that there just is very, very little communication going on at all about it. So I think for a lot of these brands, they hear about it for the first time when we talk to them about it or someone like you has talked about it. And so I think that immediate impact, I don't think we've seen it, but I think there's future impact as we really start to see how the dollars roll up and as we start to see more companies understanding what they need to do.

48:50Dr Akemi Ooka: I also don't know what the impact is going to be on innovation. There could be a tremendous impact on innovation. We're already seeing some of that in the packaging sector, really looking for different solutions for compliant packaging. But what I don't know is, will those solutions be applicable for everyone, for the beauty industry in particular? Because the beauty formulations that are sort of representative across like hair, skin, color cosmetics, personal care, like all of that, the physico-chemical properties of those formulations and the need for those formulations to be shelf stable for probably two to three years requires a level of like compatibility and protection by the packaging.

49:37Dr Akemi Ooka: And so what I don't know is whether you can get to the goals that some of these laws are requiring and still maintain the integrity of the product, the properties of the product, like that kind of thing at what's inside the bottle. And then even the bottle itself for beauty, the packaging is so integral to the brand, to the brand itself, the messaging, the look and feel of the product, the price. There's so much communicated by that packaging. There's also a lot that's functional. And if you start taking that away, I don't know what that means for the beauty industry as a whole. Like, do things start to look the same?

50:21Dr Akemi Ooka: You know, how are brands going to rely much more on deco? Even your deco has to be compliant. How will the beauty industry evolve when such an important brand vehicle is to some degree constrained from where it is today? So I think that those are big, big questions, I think, for me around like what's what's the broader impact of the beauty industry?

50:46Dr Michael Washburn: Jen, if I could tag on your notion of people not having heard about it and then tie that over to Akemi's notion of internal governance. So we have clients who are showing up even this week, just have heard about it, and many of them have learned it from their retail partners. So the larger retailers are reaching out to their suppliers and asking what their compliance posture is for various reasons. We often use the phrase with our clients that compliance is a team sport. Nobody in an organization should be surprised or not able to answer if one of their primary business partners says, where are you on EPR?

51:29Dr Michael Washburn: That needs to be a shared understanding at every level of the organization, all the way to the CEO. because it's a bad look to say, I don't know, or we haven't started, or what is that? And if you think about all the parts, we talk about the data, the reporting, understanding the characteristics of your packaging. That's all important. That's the core of the exercise. But when you register with CAA, for example, a producer has to sign a contract with CAA. It's called a producer participation agreement. So right out of the gate, you need your internal or external counsel reviewing a legal agreement.

52:05Dr Michael Washburn: To Akemi's point about making changes to your packaging, that has a profound impact, particularly on a beauty business. Those need to be shared decisions across multiple departments. And if you're a small shop, in some ways it's easier, but in some ways it's harder because you've got a lot of decisions to make. How can I get rid of plastic? Can I move to something that's more recyclable? Do I not have any options and so I have to seek an exemption, which is its own sort of exercise. You get into the process of trying to get the data. Well, a lot of companies don't possess the data on their packaging.

52:40Dr Michael Washburn: How much does it weigh? What is this thing made of, by the way? I know it's plastic. Is it a PET? Is it an HDPE? Is it a polypropylene? So they end up having to survey their suppliers to collect and curate those data to build their reports. So there's an awful lot going on here, and that itself ultimately does represent a bit of a cost, whether that's the allocation of internal staff time, or you hire a world-class consultancy like ours, or whatever it is. There's a commitment that needs to be made, and the decision really is, are we going to move to a compliant posture, or are we not? And if the answer is yes, then you need to figure out what the most efficient way is to allocate those resources, check all the boxes, get those reports out the door, and manage that internal governance.

53:34Dr Michael Washburn: It's an often overlooked puzzle piece in the larger compliance puzzle, if you will. So hopefully that context is helpful. Yeah.

53:43Dr Akemi Ooka: And I'm just thinking about the current moment where so many companies right now and individuals are kind of in survival mode. There's so much going on, like, I don't know, in Canada, as an example, I think we're in a recession. I don't know if they've said it officially, but yeah, that's the situation. And so it's understandable that if you're in survival mode, different compliance areas, especially like there's so much to know about all the different things. This is one of the things, but then it's like, what about the, I don't know, claims and how you're validating them and so on and so forth.

54:27Dr Akemi Ooka: So yeah, it's understandable that this wouldn't be something brands are thinking about, but they should be. I got a few audience questions. The first I'll ask, and then I'll lump her final question with a question that I got from my Patreon was from Heather on LinkedIn, who was the person who suggested this podcast topic. Thank you, Heather. The questions, I'll ask three questions because they're kind of related. So how do companies get ahead of the upcoming requirements? What are the best methods for tracking the required data? And is there any way to harmonize all of the requirements? Do you have any suggestions?

55:11Dr Michael Washburn: How do you track the upcoming requirements? The starting point would be the Circular Action Alliance website because to date, they are the producer responsibility organization of record for six of the seven states. So you can find a lot of resources there. There's a producer support page. There's a place where you can send an email or enter a chat with questions. But keep in mind that the producer responsibility organization is not a consultancy that's going to help you report. Their responsibility is simply to help communicate what the rules are. And they have a lot of worksheets and producer guidance documents that are available on that website that, for example, explain definitions that give you direction on how you count things.

56:03Dr Michael Washburn: There are acceptable methodologies. methodologies. Oh, I sell via e-commerce to a couple of e-commerce retailers. I don't know how much goes to Oregon versus how much goes to Colorado or California. There are methodologies to help you calculate that. So that's a good stopping spot. So that's where I would go to start to track this. Also, this might sound sort of obvious, but Google packaging EPR and read the first three articles that you find. Yes, it's true there hasn't been a focused campaign, but Akemi and I together have probably done a couple hundred conversations like this over the years.

56:42Dr Michael Washburn: Others have, other trade associations have. There's been all kinds of news coverage as the laws were passed. So it's not that hard to find if you're actually alert to it and looking for it. Okay, Jen, give me the second piece. It was tracking and then what?

56:56Dr Akemi Ooka: Is there any way to harmonize all of the requirements?

56:59Dr Michael Washburn: Sure. So different producers and different consultancies like ours do this in different ways. We actually do what we call a master data sheet. The master data sheet lays out all the SKUs that you have in your catalog and is a place to document what is the thing, what's the item, what's it called, a description, what's the material, how much does it weigh, any special characteristics. and then we carve that out, slice it and dice it to go after the appropriate scope state by state. Now, the scoping itself, this goes back to the guidance documents that CAA has. In order to really understand scoping, you have to read the statute, you have to read the regulations, and then you should look at the guidance documents.

57:49Dr Michael Washburn: And if you understand those three things, you can say, ah, I understand what's obligated in Colorado. It turns out in Colorado, for example, tertiary packaging that doesn't end up with the residential consumer is not in scope. Anything that goes business to business, not in scope. The stuff that lands in a residence, that's in scope. Okay, great. That's Colorado. Oregon is all in. California, all in. The other states are more like Colorado. So you need to understand that nuance. Can you simplify it? I'm not sure how close you can get to simple, but those are the ingredients to actually understand.

58:25Dr Akemi Ooka: I think there are a variety of tools out there. I think that ultimately they kind of do the same thing. This master data sheet, right, is if you have nothing else, start capturing this like on a spreadsheet. Like you need to start capturing and collecting the data for all of the SKUs in your portfolio, regardless of what material type is. all the way from the individual products. So the primary packaging to the secondary packaging and tertiary packaging. So just make sure you know all the way to like the product, the inner pack, the case, even to the point where like you might want to understand if you have done it, like do you have plastic that you wrap around your palette?

59:04Dr Akemi Ooka: Like just like lay it all out there and make sure that you understand what are the packaging types that you're using that are associated with that skew. If you can get more sophisticated than, you know, a spreadsheet, then I think there's also, they're starting to be, you know, product lifecycle management tools, right? PLM tools that you can use, or even enterprise resource planning tools, ERP tools that help you by, you know, they're essentially kind of like big databases that you're using to either track your in the case of PLMs, right, to track your products and make sure you understand all of the componentry and the ingredients and like have all those specs in one place.

59:49Dr Akemi Ooka: That's a really good place to collect all of your product data, right? Like your ERP is really like helping you and maybe your PLM also kind of helps you with your BOM. So like your bill of materials, like you now understand kind of what's going in to any given product. And then your ERP system, we kind of marry those two together. Like now you're thinking about your production plan and you're thinking about what's going to be produced where, and also starting to understand like what is distributed where. So there are these, you know, as you start to get a little bit larger and need some more sophistication around tracking, there are tools like that.

1:00:29Dr Akemi Ooka: I mean, And even things like, you know, we have a partnership with NetSuite, which is a division of Oracle, right? And where new and I think to some degree existing IBM members can get discounts on that kind of enterprise planning tool. And things like that can also be really helpful because then you can embed all this information automatically into product information. So if you have to pull it across the organization, like people all have access to the same data. It's not in like Herald spreadsheet on in like this folder in this like obscure place, like on his hard drive. It's like, you know, readily available for different people to access.

1:01:08And then, you know, you would clearly need some rules and guidance around like, you know, version control and how you update and who you notify.

1:01:16Dr Akemi Ooka: But I think if you've got nothing, start with the spreadsheet. And then if you have a little bit more, a more complex product portfolio and you're able to avail yourself of some of these other tools, there's a lot that's emerged around these areas. And we can help with some of that as well and point you to the right, some options. I guess in a recommendation that Akemi didn't mention that I would suggest for beauty brands navigating this stuff. Well, Michael mentioned that there are trade associations that are working on this. Like join a trade association maybe. I think that could be really helpful.

1:01:56Dr Akemi Ooka: If you're in a smaller brand, consider joining and you're based in the United States. consider joining the Independent Beauty Association that is there to serve medium to small size businesses, including in helping you understand these rules and give you updates via technical regulatory updates. They also have a really nice tool on their website and can help point you in the right direction. Like the stuff is really confusing. And that is the role of a trade association to help you so that you can all collectively understand, well, you have a lot to work to do after you get the information, but they can at least point you in the right direction.

1:02:39Dr Akemi Ooka: Okay. The other question that I got that I'm going to couple with Heather's final question was from my Patreon from Emily. For a small BC-based solid skin and hair care brand using craft boxes with stickers, paper mailers, metal travel tins, and paperboard deodorant tubes, What packaging data should I track now so I'm compliant as I grow? And which materials should I avoid because they create hidden EPR or recyclability problems? And the final question from Heather that is related to that question from Emily is, should companies that are currently exempt start collecting data?

1:03:27Dr Michael Washburn: Oh, for that last one, I would say yes. because to Akemi's point earlier, you can all turn in a moment and suddenly you're above the thresholds. It's always better to prepare and not be in a crush. So yeah, if you think you're going to grow, start now. To Emily's question, as I described that master data sheet earlier, and as Akemi rightly points out, there's all kinds of software tools that'll help you do this. Figure out all the materials on your list. Define each item. We tend to organize it by SKU And then under each SKU, if the item has different packaging layers or different components, then there's multiple rows under each SKU, right?

1:04:07Dr Michael Washburn: So we have data sheets for some of our clients that are 40 ,000 rows, right, for their portfolio, their catalog. But you need to understand specifically what those materials are, the weight of each item, you know, that paper component for the deodorant, the metal tin and its cover. And in the case of California, if you're selling there, Emily, you want to get super clear on your plastic componentry. You're going to need to document labels. If the label is on a box, you're going to classify it along with the box. But you need to separate out the plastic weight of the label and so on. So there's a lot of complexity.

1:04:44Dr Michael Washburn: And to the part of her question about what's problematic, typically multi-material components, for example, laminate films. in California, everything's going to need to be recyclable by 2032. And it's an open question of some of those formats will be recyclable by 2032. So I would look particularly at your plastics, where you've got multiple resins in one thing, you're going to want to try to move to a single resin where you can. And I'm sure Akemi has thoughts about the risks and requirements associated with that, all the things that you have to think about. So it's a bit of threading needle.

1:05:21Dr Akemi Ooka: Yeah. I mean, and I, I think you just have to record everything. I mean, like the laws right now are there's, there's a lot more interest in plastic because I think that's the more persistent problem that a lot of these are really focused on. But I mean, even California, like, I mean, you kind of have to report everything, like it's all packaging. So, and there's a compostability opportunity to, to understand. So I think, you know, even if you are making soap and you're selling it in a box, I think you should still be collecting. If you meet the thresholds or the requirements of an obligated producer, you just still register, you should still submit.

1:06:00Dr Akemi Ooka: It may mean that your fee structure is just much different, maybe a lot lower than others, depending on how the fee structures are set up. But I think you need to have all of the all of the information. And then, you know, yeah, I also agree, like from an exemption standpoint, I think you want to go ahead and make sure that you are, even if you're exempt now, just have the data because you just kind of never know. Yeah, I don't know on the resin side and what materials should you avoid? We always kind of talk about this, like, and for the beauty industry in particular, I think it's like one to struggle with.

1:06:34Dr Akemi Ooka: Like we talk about things like black packaging, right black plastic packaging you know black um it's just it's really hard to recycle and reuse like it and not hard that it's hard to recycle you like you could still have hdpe black or you know like it's recyclable but it it's very difficult to like reincorporate into something else and so i think this is one that's really difficult it just it also just kind of contaminates It's a lot of production, like when you are running black and then you need to run something with no color or a lighter color. Like there's still like a lot of traces of the black resin in there.

1:07:11Dr Akemi Ooka: So I think so that's one that I think is really challenging. But it's also a color that is like really prevalent in beauty because it has that sleek, premium, chic look to it. And so that's one that I think is something to think about. And then the other thing to think about are like metallics. Right. So some of the metallics, especially like when you think about Deco on your packaging, those can be really problematic when you're like sorting. So if you're going through like a sorting facility and they're using technology that's trying to read the package, sometimes the metallics actually get in the way of the infrared or, you know, whatever the scanner is that they're using to try to understand and identify the material.

1:07:55Dr Akemi Ooka: So if you have this package and the material is recyclable, but you cover it in something that doesn't allow you to read the package, that could be a problem. So that's something to think about. I think the other thing that a lot of people don't say, and I see this more in foods, but I could see this for smaller brands that are starting out. Having sort of mixed label and packaging can be also really problematic. So, I mean, it sounds like Emily's using boxes, but let's say that you were starting out and you were using like a PET bottle that you know is fully recyclable and maybe it's clear, it has a thing, but you put a paper label on it.

1:08:31Dr Akemi Ooka: That can be really, really difficult to separate. Effectively, what that ends up doing is contaminating the PET stream. And so, you know, we've had conversations with label suppliers who are like, hey, you know, make sure that you're really thinking about the label material. If you have a PET bottle, use PET labels. We know there are, you know, labeling companies that are really making sure the substrate that they're using when it goes through sorting or even kind of the next step where maybe you're starting to wash or prepare the containers for recycling. You know, they're making substrates that will float differently or have like a different density or something so that you can easily like separate it out.

1:09:16Dr Akemi Ooka: Paper doesn't do that. Paper just kind of like disintegrates and it's just like all over everything. You would all know this if you like try to take, you know, a food container that has a paper label on a PET package and then you're trying to wash it in the sink and it's like the paper goes everywhere and the adhesive stays on the package. So I think there's some things like that that people think they're being sustainable. Oh, I'm using a paper label, but actually it may be making it harder from a separation and sorting standpoint later. So I think there are things like that for companies maybe to have in mind.

1:09:51Dr Akemi Ooka: It's all really complicated. I find like a lot of times with environmental impact, like people want simple answers and then will gravitate towards it because that makes sense faster. But then sometimes they get turned astray because, yeah, for some of the reasons that Akemi brought up. So consider hiring good consultants who can help you navigate this space. And that requires substantial subject matter expertise. There's so much complexity from EPR stuff, but then also little details around it. So yeah, vet your consultants, hire consultants or the staff that you hire, whatever. Yeah, hire good ones.

1:10:46You know, I think there are a lot of people that are, you know, putting the shingle out

1:10:50Dr Akemi Ooka: saying that they do EPR, but... Check that they have experience. Yeah, make sure that they know what they're doing, what they're talking about, and, you know, that they've got a good kind of history in the space.

1:11:01Dr Michael Washburn: Yeah, I'll give a hack to the listeners just on vetting consultants, because we're routinely approached by folks who have the latest, greatest data solution software answer to the complexity. If somebody is approaching you and they're using data in every sentence and you ask them how they handle scoping and they look confused, they're not your consultant. it's wildly important that you get your scope right so that you don't report for things that you're not obligated and so that you do report for things where you are. And I have witnessed firsthand that there's a lot of folks who think it's all about the data, but don't really understand the complexity underneath.

1:11:50Dr Michael Washburn: So hopefully that's a helpful screening tool.

1:11:53Dr Akemi Ooka: Yeah, that's actually so important. It's like with any regulatory, know what you are being required to do. You don't have to like give a whole lot more information. There's like something specific they're asking for, meet what they're asking for, you know, and really kind of focus on that. I think that that's really, that's great advice. Do you have any final take homes that you'd like to leave with my audience and or messages that we haven't had a chance to get out there that you'd like to insert in this conversation? EPR is one of a number of compliance requirements in the beauty industry. And I would just encourage all of you, if you're not a member of IBA, it is a corporate-based membership.

1:12:36Dr Akemi Ooka: So you have to join kind of as a company, even if you're a single person, if you have a consultancy, if you're a single founder brand, you can join. But I think that it's worth joining IBA, even if it's just keep on top of all of these developments. You know, like what are the what are the latest compliance requirements? What are the develops? It is not sexy. Like I completely admit that it's not as sexy as like who sold their brand for whatever. But this is sort of the nuts and bolts behind, you know, running a successful business and in the beauty industry. And in more and more, this kind of compliance work is showing up in due diligence evaluations for M &A and in that kind of activity.

1:13:20Dr Akemi Ooka: So to shamelessly plug IBA, like I will say, you know, come check us out at independentbeauty.org. Let us help you.

1:13:27Dr Michael Washburn: And the last thing I'll say is just, yes, it can be overwhelming, but people have done it. They've done it successfully. It's not rocket science. It takes a little bit of work. Phone a friend. Don't go in alone. There's lots of tools. There's lots of consultancies out there like us who are here to help, as well as, as Akami points out trade associations and IBA in particular. So don't feel alone. There's lots of folks you can talk to. Talk to your peers. Get a consultant. We'll figure it out together.

1:14:01Dr Akemi Ooka: Big thanks to Akemi and Michael for sharing your expertise with us on the podcast. I hope you learned a lot and enjoy that conversation. Quick reminder, if you're not already subscribed to the podcast, please do. And if you haven't already, please give the podcast a review. If you enjoyed this episode, please share. And if it's accessible, you can also support the podcast on Patreon at patreon.com slash the eco L. Thank you again to all my Patreon supporters who've supported my science communication efforts over the years. That's all for this week. Thanks for tuning in.