Sixth Circuit -- American Beverage Association v. Snyder

No Dormant Commerce Clause violationin Michigan's requirement that all recyclable cans carry a mark unique to the state, as any manufacturer is free to put the mark on the can.

No discriminatory effect, for same reason.

However, the labeling requirement is extraterritorial burden on manufacturers, and therefore violates the DCC

Concurrence: Extraterritoriality, schmextraterrritoriality

 American Beverage Association v. Snyder