Packaging EPR Laws in the U.S.

Packaging EPR laws in the U.S. are rapidly expanding, requiring companies to take financial and operational responsibility for the packaging they place on the market. Several states have already established producer obligations, and implementation is moving at different speeds in each one. Some are already collecting fees, while others have hit delays. Below, we break down the key requirements, covered products, and current deadlines in each state. 

This list reflects packaging extended producer responsibility (EPR) laws currently in effect or under active implementation as of this writing; it does not cover every producer responsibility law in the U.S. or laws still in earlier stages of the legislative process. Deadlines and program status can change; check the linked state agency page for the most current information. 

California: Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54)

By 2032, producers must ensure that all single-use packaging and plastic food serviceware sold in California is recyclable or compostable. They are also required to reduce their use of plastic packaging by 25%. At least 65% of single-use plastic packaging and food serviceware must be recycled.  

Producers join a CalRecycle-approved PRO to carry out compliance. Circular Action Alliance is currently the only state-approved PRO in California. 

Covered products: 

• Single‐use packaging (including plastic) 

• Single‐use plastic food serviceware (e.g., plates, cups, containers) 
  

Key dates & deadlines: 

• May 1, 2026: Permanent regulation approved; the Act takes effect. 

• June 1, 2026: Producers must have registered with an approved PRO, registered individually with CalRecycle, or applied for an exemption. 
  
• January 1, 2027: Producers may not sell covered materials in California without participating in an approved program. 
• 2032: Full compliance required — recyclable/compostable standards and plastic reduction targets in effect. 

Some aspects of SB 54's implementation have faced legal challenges in 2026; the program remains in effect for all producers.

Colorado: Producer Responsibility Program for Statewide Recycling Act (HB 22-1355)

Producers of packaging and paper products must participate in a producer responsibility program, either by joining the state-appointed PRO or submitting their own approved plan. Producers fund and help manage a coordinated, statewide recycling system that increases access and recycling rates across Colorado. 

The Colorado Department of Public Health and Environment oversees implementation. Circular Action Alliance (CAA) is the appointed PRO for most producers; the Lubricants Packaging Management Association (LPMA) operates as a separate independent PRO for petroleum and automotive packaging. 

Covered products

• Packaging materials (primary and secondary) 
• Paper products (printed paper and paper packaging) 

Key dates & deadlines

• October 1, 2024: Producer registration deadline. 
• July 1, 2025: Sales ban for covered products if producers are not compliant. 
• 2026 onward: Annual producer dues required to fund the program. 

Colorado's producer responsibility structure has drawn legal challenges from industry groups in 2026, though the program remains fully in effect. 

Maine: Stewardship Program for Packaging (LD 1541) 

Producers of packaging must fund a statewide stewardship program that shifts recycling and waste management costs from municipalities to producers. Producers will pay fees based on the type and amount of packaging supplied into Maine. 

The Department of Environmental Protection is currently assessing its options and will post updates to the program's timeline on its website. Producer registration, reporting, and fee obligations are on hold pending selection of a Stewardship Organization. 

Covered products

• Packaging material supplied to Maine consumers 

Key dates & deadlines

• December 5, 2024: Board of Environmental Protection adopted final program rules. 
• June 15, 2026: Maine DEP published a Request for Proposals (RFP) for a Stewardship Organization to manage the program. 
• August 18, 2026: RFP deadline passed with no proposals submitted. Circular Action Alliance, the PRO active in California, Colorado, Maryland, Minnesota, Oregon, and Washington, publicly confirmed it did not submit a bid. 

Selling into the EU too? PPWR is changing the rules there.  

The EU's Packaging and Packaging Waste Regulation (PPWR) expands existing EPR obligations with new requirements for recyclability, recycled content, and packaging design. Watch our webinar, Navigating the PPWR, to understand how it builds on the EPR fundamentals and what to prepare for next. 

Maryland: Packaging Materials and Paper Products: Producer Responsibility Plans (SB 901)

SB 901 requires producers of covered materials to participate in a Producer Responsibility Organization (PRO) or act individually by submitting a producer responsibility plan to the Maryland Department of the Environment (MDE). Producers may not sell, import, or distribute covered materials in Maryland unless operating under an approved plan. 

MDE reviews and approves producer responsibility plans. An advisory council assists in evaluating plans and program outcomes. 

Covered products: 

• Packaging materials 
• Paper products 

Key dates & deadlines: 

• June 1, 2026: MDE's first implementing regulations take effect. 
• May 31, 2026: Producers must submit simplified supply reports to CAA. 
• July 1, 2026: PROs must register with MDE. 
• July 1, 2028: Producers, individually or as part of a PRO, must submit their first producer responsibility plans. 
• Every five years thereafter: Producers, individually or as part of a PRO, must update and resubmit plans. 

Minnesota: The Packaging Waste and Cost Reduction Act (HF 3911/SF 3561) 

Producers of packaging, paper products, and food serviceware sold or distributed in Minnesota must participate in a PRO or submit their own plan. By 2032, producers will be responsible for financing and implementing a system to reduce packaging waste and increase recycling and composting. 

MPCA oversees the program. The PRO collects fees, reimburses service providers, and submits updated stewardship plans every five years. 

Covered products

• Packaging and packaging components 
• Paper products 
• Food serviceware 

Key dates & deadlines

• February 2025: Minnesota Pollution Control Agency (MPCA) selected Circular Action Alliance (CAA) as PRO. 
• July 1, 2025: Producers must have registered with CAA. 
• May 31, 2026: Producers must submit simplified supply reports to CAA. 
• July 1, 2026: CAA must register with MPCA, including a list of participating obligated producers and brands. 
• December 31, 2026: MPCA must complete its needs assessment. 
• August 1, 2028: PRO stewardship plan submitted to the Advisory Board. 
• October 1, 2028: PRO stewardship plan due. 
• February 1, 2029: Producers must operate under the approved stewardship plan and cover at least 50% of the costs. 
• February 1, 2030: Producers cover at least 75% of stewardship plan costs 
• February, 2031: Producers cover at least 90% of stewardship plan costs. 
• 2032: All covered products must be reusable, refillable, recyclable, or compostable. 

Oregon: Plastic Pollution and Recycling Modernization Act (SB 582) 

Producers of packaging, paper products, and food serviceware must join a PRO and pay fees that fund statewide recycling improvements. The law aims to modernize Oregon's recycling system by expanding access, reducing environmental impacts, and increasing transparency. 

Oregon’s Department of Environmental Quality (DEQ) oversees the program and has approved CAA as the PRO to carry out implementation and compliance. 

Covered products

• Packaging materials 
• Paper products 
• Food serviceware 

Key dates & deadlines

• March 2024: First draft of program plan submitted by CAA. 
• September 2024: Second draft of program plan submitted. 
• February 21, 2025: DEQ approved the final program plan. 
• July 1, 2025: CAA began implementing the program statewide. 
• July 2026: CAA have started to work on the development of their 2028-2032 program plan. 

Oregon's program faced a legal challenge in 2026; a federal court upheld the law following trial. 

Washington: Postconsumer Recycled Content & Recycling Reform Act (RCW 70A.245.020 + SB 5284, 2025)

Under RCW 70A.245.020, Washington requires producers of certain plastic products to use minimum percentages of post-consumer recycled material in their products, register with the state, and meet escalating recycled content thresholds. Under 70A.208 RCW (the Recycling Reform Act), producers of packaging and paper products must join or form a Producer Responsibility Organization (PRO) or file their own plan and take responsibility for improving recycling services statewide.  

Oversight is handled by the Washington Department of Ecology. Producers must register, pay fees sufficient to cover administration and enforcement costs, and submit annual reports. 

Covered products

• Plastic beverage containers (excluding wine in 187mL and dairy milk containers until January 1, 2028) under RCW 70A.245.020 
• Plastic trash bags under 70A.245.020 
• Plastic household cleaning & personal care product containers under RCW 70A.245.020 
• Packaging and paper products more broadly under the EPR / PRO framework of 70A.208 RCW 

Key dates & deadlines

Recycling Reform Act  

• January 1, 2026: Each producer must appoint a PRO to address its covered materials. 
• March 1, 2026, and annually thereafter: PROs must register with the Department of Ecology on behalf of producers. 
• July 1, 2026: Producers must either be part of a registered PRO or register as an individual PRO with their own plan. 
• September 1, 2026: PROs must make a one-time payment to the Department. 
• December 31, 2026: Statewide preliminary needs assessment due. 
• May 1, 2027, and annually thereafter: PROs submit registration fees to fund program oversight. 
• December 31, 2027: Statewide full needs assessment due. 
• June 1, 2028: Department of Ecology must adopt rules to administer and implement the Recycling Reform Act. 
• August 1, 2028: Each registered PRO must submit a draft plan to the advisory council. 
• October 1, 2028: Each registered PRO must submit a draft plan for Department approval. 
• March 2029: Producers who are not members of a PRO cannot sell their products in Washington.
•  July 1, 2029: Department approves PRO plans 
• January 1, 2030 (or within six months of plan approval, whichever is later): Approved plans must be implemented. 
• July 1, 2031, and annually thereafter: PRO submits program report to Department. 
• 2034: PRO submits updated program plan to Department. 

Postconsumer Recycled Content

• April 1, 2022: Producers must register with the Department of Ecology individually or through a third-party representative registering on behalf of a group of producers. 
• January 1,2023: Plastic beverage containers (excluding wine in 187mL and dairy milk containers and plastic trash bags must meet the minimum postconsumer recycled content requirements 
• January 1, 2025: Plastic household cleaning and personal care product containers must meet the minimum postconsumer recycled content requirements 
• January 1, 2028: Plastic beverage containers including wine in 187mL and dairy milk containers must meet the minimum postconsumer recycled content requirements 

Staying ahead of shifting state-level EPR requirements

Tracking deadlines across different state programs—each moving at its own pace, with its own PRO, and its own reporting cadence—isn't something most teams can manage in a spreadsheet for long. When packaging data lives across ERP, PLM, and warehousing systems, reporting becomes a scramble, and a missed deadline turns into real financial exposure. 

Our EPR solution supports that process by: 

• Integrating data from ERP, PLM, and warehousing systems for real-time visibility 
• Simplifying data collation to generate accurate reports for each jurisdiction 
• Automating evaluation of eco-modulation fees to anticipate and plan for cost impacts 
• Supporting report building and submission with flexible delivery 
• Monitoring regulatory changes in real time, including tariffs and reporting schedules 

Producers are already turning fragmented, manual EPR reporting into a centralized, audit-ready process with Source Intelligence. See how Arla Foods did it—and recovered more than $1M in overpaid fees along the way: Arla Foods Simplifies Global EPR Reporting.