Retailers

In some cases, a retailer may also meet the definition of a producer in which case, they would have both the
responsibilities as a retailer and a producer, pursuant to 115A.1416 subd. 1(d).

What is a Retailer?

“Retailer” means a person that sells or offers boat wrap for sale in or into this state by any means.

This definition broadly applies to marinas, boat dealers, storage facilities, and any other entity selling boat wrap in or into Minnesota and includes all forms of sales (e.g., direct sales of the product via online or physical retail, sales as a part of a service).

Retailers are responsible for reviewing the posted list of producers on the MPCA website to confirm compliance before purchasing or selling boat wrap.

KEY RESPONSIBILITIES

Retailers and Wholesalers

1. Routinely check the MPCA website for the most up-to-date list of compliant producers before placing orders to purchase boat wrap

2. Record the date of each boat wrap order and supplier name and retain printed or digital proof of status on the date of purchase

3. Subscribing to updates from the stewardship organization (CIFFRO) and the Minnesota Pollution Control Agency (MPCA) to receive timely alerts regarding the compliance status of existing producers or new producers entering the program

4. Communicate law requirements with your purchasing and retail staff

5. Conduct a monthly inventory review and audit recent purchases for continued compliance

Additionally:

  • A retailer or wholesaler is not in violation of these responsibilities if, on the date the boat wrap was ordered, the producer was listed as compliant on the MPCA website.

  • A retailer may elect to participate as a designated collection point for boat wrap as part of a stewardship program approved under the law.

  • Wholesaler is not defined within the statute. In the absence of a definition in statute, courts may look to dictionary definitions to determine the plain and ordinary meaning of a word. In the context of the statute, common definitions of a wholesaler refer to a person selling primarily to retailers or businesses for resale.

  • A wholesaler is identified in the statute as having the same responsibilities as a retailer, which is to review the list of compliant producers and only purchase product from those participating producers. Wholesalers may also have producer responsibilities if they fall under any of the producer definitions.

Retailer Resources

STEPS TO RECYCLE PROPERLY

  • Program overview and purpose
  • Legal context and MN statutes
  • Instructions for preparing boat wrap

WHY RECYCLING IS IMPORTANT

  • Who can participate in the program
  • When and where to recycle
  • What happens to recycled boat wrap
  • Why recycling matters

Questions? We Have Answers!

Retailers support the program by ensuring that the producers they purchase from are compliant with the stewardship requirements and that all orders meet regulatory standards. Their ongoing oversight helps maintain the integrity of the WRR system, ensures proper recordkeeping, and promotes consistent participation in the recycling network.