As more EPR legislation comes into effect over the next year, businesses will have to spend considerable time and effort addressing these new regulatory requirements. While many states are finalizing their fees and additional rules, many have already released timelines for data tracking and reporting. The time is now to both assess how these laws will affect your business and integrate avenues of action into your compliance strategy.
Oregon
Oregon’s EPR program is now fully in effect. The deadline for reporting sales volumes is May 31st, where producers must detail all covered materials sold into the state during the 2025 calendar year. Requirements include mandatory membership in an approved Producer Responsibility Organization (PRO) of which there is only one currently, the Circular Action Alliance (CAA), the payment of annual fees, and adherence to the state’s “Uniform Statewide Recyclable List.”
Colorado
Colorado’s EPR plan officially took effect January 1st this year. This marks the first year Colorado producers will pay mandatory responsibility fees based on the volume and classification of packaging. To remain compliant, companies must register with the CAA and submit their detailed material supply reports by May 31, 2026. Dues for 2027 will be released in October of this year.
California
California’s EPR program begins January 1st, 2027. This being said, 2026 is still a critical preparatory year. Producers are required to submit their material data supply by May 31st, 2026, which the state will use to calculate the first round of “early-fees” due in August. Additionally, brands must begin auditing their portfolios to ensure all packaging is on track to be 100% recyclable or compostable by 2032. Additionally, California’s EPR legislation requires that by 2032 65% of single-use plastic must be recycled, and the weight of single-use plastic packaging must be 25% less that of 2023 baseline levels.
Maine
Maine is selecting its Stewardship Organization (SO) in early 2026, which most expect to be the CAA, setting the stage for a rollout that emphasizes small business simplicity. By the third quarter of this year, producers will be required to register through a new portal and pay initial startup fees to fund the program’s launch. Unlike other states, Maine offers a flat fee reporting option for mid-sized producers (1 to 15 tons of packaging), but all non-exempt businesses must prepare for a simplified supply report due in late 2026 to establish their baseline obligations.
Maryland
Following the signing of SB 901 in May 2025, Maryland’s program is now moving into its first major compliance window. All obligated producers must register with the approved PRO (currently the Circular Action Alliance) by July 1st, 2026. Prior to this, a simplified supply report based on 2025 data is due on May 31st, 2026. The law outlines a phased reimbursement schedule for local governments, starting at 50% of recycling costs in 2028 and reaching 90% by 2030. Exemptions are available for producers with less than $2 million in global gross revenue or those providing less than 1 ton of covered material annually.
Minnesota
Following the passage of the Packaging Waste and Cost Reduction Act in 2024, Minnesota is spending 2026 in the “Needs Assessment” and foundation-building phase. While full fees aren’t due for a few years, producers are required to have joined the PRO (again, the CAA) as of late 2025 and must participate in the statewide simplified reporting cycle on May 31st, 2026. This data is crucial for the Minnesota Pollution Control Agency as they finalize the infrastructure gaps that producers will be expected to fund which may be up to 90% of the state’s total recycling costs by 2031.
Washington
Washington’s Recycling Reform Act, passed in 2025, is moving quickly to catch up with its West Coast neighbors. By January 1st, 2026, all obligated producers were required to appoint a PRO, with the formal registration of that PRO with the Department of Ecology occurring by March 1st. The immediate requirement for 2026 is the submission of a simplified material supply report by May 31st. Producers should be aware that Washington has more limited small-business exemptions compared to Oregon or Colorado, meaning even smaller brands must ensure they are in “good standing” to avoid potential sales bans.
Conclusion
Navigating the EPR landscape effectively requires a shift from reactive reporting to proactive packaging design. With many states now sharing a harmonized May 31st reporting deadline through the Circular Action Alliance, the administrative burden is becoming more streamlined, but the financial stakes are higher than ever. To stay ahead, brands should focus on material transparency, data accuracy, and packaging design today to mitigate the fees of tomorrow. Trayak provides services for EPR reporting as well as third-party reviewed LCA as required for Oregon bonuses. Reach out today if you have questions or would like more information on our services.
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