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For the manufacturer “take-back” pathway under Option 2, does the extended producer responsibility program have to be run by the manufacturer?

No, product take-back programs can be run by trade associations and/or government agencies as well, as long as they provide documentation that they are actually recycling most of the material that they collect. 

Question: 

For the manufacturer “take-back” pathway under Option 2, does the extended producer responsibility program have to be run by the manufacturer?