Packaging extended producer responsibility (EPR) regulations are rapidly expanding across the U.S., requiring companies to take financial and operational responsibility for the packaging they put on the market. As of 2025, seven states have enacted packaging laws, with more states preparing to follow. These laws vary in scope, covered products, and compliance timelines, creating complex challenges for producers. Below, we break down the key requirements in each state to help you understand what’s in effect.
Which U.S. states have packaging EPR laws?
As of 2025, seven states have enacted packaging EPR laws: Maryland, Washington, Minnesota, Colorado, California, Oregon, and Maine.
2025 EPR highlights:
- Oregon: PRO plan approved; implementation began July 1, 2025.
- Colorado: Producers had to enroll and submit supply reports by July 31, 2025; eco-modulation schedule required by January 1, 2026.
- California: Permanent SB 54 regulations in formal rulemaking (Aug 22–Oct 7, 2025).
- Maine: Program rules adopted by the Board of Environmental Protection.
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.
Covered products:
- Packaging materials
- Paper products
Key dates & deadlines:
- June 1, 2025: Law takes effect
- July 1, 2026: PROs must register with MDE
- July 1, 2028: Producers must submit their first producer responsibility plans
- Every five years thereafter: Producers must update and resubmit plans
MDE reviews and approves producer responsibility plans. An advisory council will assist in evaluating plans and program outcomes.
Washington – Postconsumer Recycled Content & Recycling Reform Act (RCW 70A.245.020 + SB 5284, 2025)
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 SB 5284 (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.
Covered products:
- Plastic beverage containers (excluding wine in 187mL and dairy milk containers until later deadlines)
- Plastic trash bags
- Plastic household cleaning & personal care product containers
- Packaging and paper products more broadly under the EPR / PRO framework of SB 5284
Key dates & deadlines:
- January 1, 2026: Each producer must appoint a PRO (or multiple PROs) 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.
- May 1, 2027: and annually thereafter, they must submit registration fees to fund program oversight.
- October 1, 2028: and every five years thereafter – Each registered PRO must submit a plan for Department approval.
- January 1, 2030 (or within six months of plan approval, whichever is later): Approved plans must be implemented.
Oversight is handled by the Washington Department of Ecology. Under RCW 70A.245.020, producers must register (individually or via third-party representatives), pay fees sufficient to cover costs of administration, rulemaking, and enforcement, and submit annual reports. Under SB 5284, the PRO must submit plans, and non-registered producers may be prohibited from selling covered materials.
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. They must also ensure that utilized materials meet reuse, refill, recycling, or composting standards.
Covered products:
- Packaging and packaging components
- Paper products
- Food serviceware
Key dates & deadlines:
- January 1, 2025: Producers must designate a PRO.
- July 1, 2026: PRO must register with the Minnesota Pollution Control Agency.
- October 1, 2028: PRO submits a stewardship plan.
- January 1, 2029: Producers must operate under an approved stewardship plan.
- 2032: All covered products must be reusable, refillable, recyclable, or compostable.
The Minnesota Pollution Control Agency will oversee the program. The PRO will collect fees, reimburse service providers, and submit updated stewardship plans every five years.
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 will fund and help manage a coordinated, statewide recycling system that increases access and recycling rates across Colorado.
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
The Colorado Department of Public Health and Environment oversees implementation. Circular Action Alliance (CAA) has been appointed as the PRO responsible for managing compliance and system operations.
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.
Covered products:
- Single‐use packaging (including plastic)
- Single‐use plastic food serviceware (e.g., plates, cups, containers)
Key dates & deadlines:
- July 1, 2024: CalRecycle must publish list of covered material categories.
- January 1, 2025: Producers of expanded polystyrene (EPS) food serviceware must demonstrate 25% recycling rate. A failure to do so means such EPS cannot be sold/imported/distributed in CA.
- 2025 (Aug–Oct): Formal rulemaking period with public comment on SB 54 regulations.
- 2032: Full compliance required — recyclable/compostable standards and plastic reduction targets in effect.
Producers will join a CalRecycle-approved PRO to carry out compliance. The law also includes an advisory board, periodic needs assessment, and oversight by CalRecycle.
Note: Circular Action Alliance is currently the only state-approved PRO in California
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.
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
- December 2024: DEQ approved the final program plan
- July 1, 2025: CAA begins implementing the program statewide
DEQ oversees the program and has approved CAA as the PRO to carry out implementation and compliance.
Maine - Stewardship Program for Packaging (LD 1541, amended by LD 1423)
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.
Covered products:
- Packaging material supplied to Maine consumers
Key dates & deadlines:
- December 5, 2024: Board of Environmental Protection adopted final program rules
- 2026: Producers required to begin program registration and reporting
- 2027: Municipal reimbursements expected to begin once program is operational
How Source Intelligence simplifies U.S. packaging EPR compliance
Managing EPR for packaging across multiple states means navigating evolving rules, shifting reporting schedules, and rising costs. With data scattered across systems and deadlines looming, manual reporting becomes time-consuming and error-prone, increasing the risk of missed obligations.
Our EPR solution streamlines compliance by:
- Simplifying data collation to generate accurate reports for each jurisdiction
- Integrating data from ERP, PLM, and warehousing systems for real‑time visibility
- Monitoring regulatory changes in real time, including tariffs and reporting schedules
- Automating evaluation of eco‑modulation fees to anticipate and plan for cost impacts
- Supporting report building and submission with flexible delivery
With Source Intelligence, you stay ahead of shifting state requirements while reducing the risk of penalties and costly rework. Our automated workflows replace manual processes, freeing your teams from administrative burdens and ensuring accurate, audit-ready reporting. Instead of scrambling to keep up, you gain a scalable system that keeps compliance on track and empowers you to focus on long-term sustainability goals.
Learn more about how our solution can help you manage your EPR compliance with less risk.
