The Washington Department of Ecology has acknowledged Interchange 360, a nonprofit producer responsibility organization (PRO), as the entity planning to implement an Alternative Collection Program (ACP) for petroleum-related packaging.
The designation enables companies that produce lubricants, petroleum products, and certain automotive packaging to meet compliance requirements through a collection and recycling structure designed specifically for those materials rather than relying on traditional household recycling systems.
Washington’s RRA, signed into law in 2025, created a statewide producer-funded recycling framework for residential packaging and paper. Producers that place packaging on the market must finance and manage recycling programs through state-approved PROs.
Circular Action Alliance has already been selected to run the broader packaging EPR program. The proposed Interchange 360 system would operate alongside that structure, focusing on packaging types that are not typically suited to curbside recycling infrastructure.
Packaging used for lubricants and automotive fluids often presents logistical and safety challenges that differ from standard consumer packaging streams.
Containers can retain residual product, require specialized handling during transport, or move through collection systems tied to auto shops and service centers rather than household recycling programs.
The Alternative Collection Program model within Washington’s recycling law is intended to accommodate these realities. Instead of forcing all materials into a single statewide recycling system, the structure allows regulators to approve sector-specific programs that better match existing industry practices.
By acknowledging Interchange 360’s proposed ACP, the Department of Ecology signaled that dedicated infrastructure may be necessary to safely collect and recycle petroleum-related containers.
The organization has indicated it plans to coordinate with producers, regulators, and industry stakeholders across Washington to establish collection pathways and recycling systems aligned with both regulatory requirements and current automotive-sector operations.
Washington’s move may also signal how EPR frameworks in other states could evolve as more jurisdictions adopt producer-funded recycling laws.
While curbside recycling programs cover a large portion of consumer packaging, certain materials—including automotive and industrial packaging—often require different recovery networks.
Allowing specialized stewardship programs to operate alongside broader packaging EPR systems could help regulators maintain efficiency while improving recovery outcomes for materials that fall outside traditional municipal collection streams.
For producers navigating an expanding patchwork of state recycling laws, Washington’s ACP structure offers a potential compliance model tailored to specific product categories while still operating within the larger EPR framework.
