US Packaging EPR by State
Which states affect your business—and what should you do next? Compare seven state programs, then follow the official sources for reporting, fees and producer responsibilities.
Last reviewed: · Dave Chiddy
At a glance
| State | Status | Producer action | Reporting / fees |
|---|---|---|---|
| California | Regulations effective; plan under review | Confirm coverage and PRO participation; prepare category-level data. | Check PRO reporting and fee instructions. |
| Oregon | Operating; reporting and fees active | Register with the approved PRO, report and pay if obligated. | Annual prior-year supply reporting to CAA by May 31. |
| Washington | Implementation; membership requirement active | Join a registered PRO or register for an individual plan. | Confirm initial implementation fees with the PRO. |
| Colorado | Approved program; 2026 dues active | Participate, register and submit supply reports. | Dues apply from January 2026 and annually thereafter. |
| Maryland | Registration and program development | Use MDE’s compliance guide to confirm registration and exemptions. | Verify the applicable route and timetable with MDE and the PRO. |
| Maine | Stewardship organization procurement | Prepare packaging records; monitor DEP’s revised schedule. | Producer registration follows the SO mechanism becoming available. |
| Minnesota | 2025–2026 foundation phase | Confirm producer status and PRO membership; prepare supply data. | Program costs phase in during implementation. |
This seven-state comparison is a practical starting point, not an exhaustive US jurisdiction register. Coverage, exemptions and deadlines depend on the producer and product. Follow the linked agency and your PRO for current instructions.
California SB 54
Read the California SB 54 producer guide →
SB 54 covers single-use packaging and single-use plastic food service ware across sectors. Permanent regulations took effect on May 1, 2026. CalRecycle received CAA’s proposed producer responsibility plan on October 13, 2026; receipt does not mean approval.
Who should act?
Review the producer definition and exemptions before allocating responsibility. Map components to the current Covered Material Categories list and retain evidence for material, weight and any claimed exclusion. Treat reporting, producer fees, source reduction and recyclability requirements as separate workstreams.
What to do next
Monitor CalRecycle’s plan review and updated producer guidance. A lighter pack does not by itself establish compliance with the law’s design or source-reduction requirements.
CalRecycle: official requirements and guidance · Last reviewed: 17 October 2026.
Next: confirm your obligations, assemble your packaging data and forecast fees.
Oregon
Oregon’s Recycling Modernization Act requires obligated producers of covered packaging, paper and food serviceware to register, report supply and pay PRO membership fees. Small producers meeting the statutory definition are exempt.
Who should act?
DEQ identifies CAA as the only currently approved PRO. The initial March 31, 2025 deadline for 2024 supply has passed. From May 31, 2026, prior-year supply data are due by May 31 each year. Fee payment dates are set by CAA.
What to do next
Reconcile outstanding 2024 and 2025 reporting and 2025–2026 fee payments. The 25 largest producers by weight have additional life-cycle evaluation duties.
Oregon DEQ: official requirements and guidance · Last reviewed: 17 October 2026.
Next: confirm your obligations, assemble your packaging data and forecast fees.
Washington
Read the Washington packaging EPR guide →
RCW 70A.208.040 requires producers, after July 1, 2026, to belong to a registered PRO or register as a PRO implementing an individual plan.
Who should act?
The statute provides for initial producer fees before an approved plan. PRO plans are due October 1, 2028. Plan implementation is January 1, 2030 or six months after approval, whichever is later.
What to do next
Market-access restrictions begin March 1, 2029 for producers without the required membership or individual plan. Do not confuse this date with the earlier membership obligation.
Washington Legislature: official requirements and guidance · Last reviewed: 17 October 2026.
Next: confirm your obligations, assemble your packaging data and forecast fees.
Colorado
Colorado’s producer responsibility program requires participation for products using covered materials, subject to applicable exemptions. CDPHE approved CAA’s program plan in December 2025.
Who should act?
CDPHE states that covered producers must keep compliance records and report data. Its guidance identifies participation requirements from July 2025 and dues from January 2026.
What to do next
Check the applicable route: certain petroleum and automotive packaging falls under Interchange 360’s individual program. Some producers may need both routes.
Colorado CDPHE: official requirements and guidance · Last reviewed: 17 October 2026.
Next: confirm your obligations, assemble your packaging data and forecast fees.
Maryland
Maryland’s Packaging and Paper Products – Producer Responsibility Plans Act was signed on May 13, 2025. MDE publishes final regulations, producer registration information and a September 2026 compliance guide.
Who should act?
Confirm which entity is the producer and whether an exemption or exclusion applies. MDE provides a determination request process and a list of producers and brands reported by CAA.
What to do next
Use the packaging and paper section of MDE’s page; paint stewardship is a separate program. Do not infer packaging fee dates from paint-program materials.
Maryland MDE: official requirements and guidance · Last reviewed: 17 October 2026.
Next: confirm your obligations, assemble your packaging data and forecast fees.
Maine
Maine’s packaging stewardship program is at the stewardship organization contracting stage. DEP reports that it is reassessing the implementation schedule and will publish a revised schedule after SO selection.
Who should act?
DEP states that producers must register within 90 days of the SO making a registration mechanism available. Annual reporting and fees follow the program’s implementation.
What to do next
The published recurring annual schedule is not a confirmed first-year start date. Track the SO procurement and revised timetable before treating an annual date as a current filing deadline.
Maine DEP: official requirements and guidance · Last reviewed: 17 October 2026.
Next: confirm your obligations, assemble your packaging data and forecast fees.
Minnesota
Minnesota’s Packaging Waste and Cost Reduction Act covers packaging, food packaging and paper products, including online purchases and shipments, subject to exemptions. MPCA has accepted CAA’s initial PRO registration.
Who should act?
The 2025–2026 phase covers assessments and program foundations; 2027–2028 establishes program structure. Implementation and cost coverage follow during 2029–2032.
What to do next
MPCA is accepting comments on the draft 2026 needs assessment through November 13, 2026. Track collection lists, statewide requirements and stewardship planning.
Minnesota MPCA: official requirements and guidance · Last reviewed: 17 October 2026.
Next: confirm your obligations, assemble your packaging data and forecast fees.