Short answer: Maine's Stewardship Program for Packaging is structured differently from the PRO-led programs in Oregon and Colorado. The Maine Department of Environmental Protection (DEP) contracts with a stewardship organization that runs day-to-day operations. As of October 2026, DEP had not yet selected that organization: its solicitation received no proposals, and DEP announced it would revise the request and reassess the implementation schedule.
How Maine's program is structured
Maine enacted its packaging stewardship law in July 2021 (38 M.R.S. § 2146). Unlike states where producers form or join a PRO that submits its own plan, Maine's model centers on a stewardship organization (SO) under contract with DEP. DEP oversees the SO and alternative collection programs; the SO handles producer registration, reporting, invoicing and payments to municipalities. The program is designed primarily to reimburse municipalities for eligible recycling and disposal costs.
Do not assume Maine works like a CAA-administered state. Registration, reporting and payment run through whichever SO DEP contracts with.
Program facts
Current status, as published by Maine DEP
- The Board of Environmental Protection adopted the program rule, Chapter 428, in December 2024.
- In March 2026, Chapter 428 was amended to add Appendix A, the Packaging Material Types List, and to align with June 2025 changes to the law.
- DEP's stewardship organization solicitation received no proposals by its August 2026 deadline. On September 11, 2026, DEP announced it would revise the request for proposals.
- DEP describes the program as at step four of nine (contracting with an SO) and is reassessing the implementation schedule.
Producer requirements once the program is operating
DEP describes these producer obligations, which take effect once an SO is under contract and has a registration mechanism available:
| Requirement | Timing described by DEP |
|---|---|
| Register with the stewardship organization | Within 90 days after the SO makes registration available |
| Report packaging by material type | Annually, by May 31 |
| Receive invoice | By July 1 |
| Pay the stewardship organization | By September 1 |
Packaging material characterization
Maine reports are organized by packaging material type. The Packaging Material Types List added to Chapter 428 in March 2026 defines those categories. Producers will need component-level packaging data mapped to Maine's list, which may not line up one-to-one with categories used in other states.
Fee concept
Producer payments fund reimbursement of municipal costs and program administration, calculated from the packaging material a producer reports. Maine's law anticipates that payments reflect material type, including recyclability. Actual rates will depend on the SO and DEP's implementation.
Exemptions
DEP lists several exemptions, including:
- Producers with less than $2,000,000 in gross annual revenue for the first three years after the SO contract takes effect, and less than $5,000,000 from program year four.
- Producers whose Maine sales used less than one ton of packaging material.
- Producers earning more than 50% of gross revenue from insurance salvage, closeouts, bankruptcies and liquidations.
- The first 15 tons of packaging used for perishable food products sold in or into Maine in the prior year.
DEP also describes simplified reporting and a flat-fee option for low-volume producers. Confirm current details with DEP.
CertaRelay recommendation
Use the delay productively. Maine's material list is published, so you can map your packaging data to it now and be ready to register within the 90-day window once an SO is selected.
What your team should prepare
- Units sold into Maine by SKU, or a method to estimate them from distributor data.
- Component-level packaging data that can be mapped to Maine's Packaging Material Types List.
- Revenue and tonnage information relevant to Maine's exemptions.
- An owner who will watch for DEP's SO announcement and the registration window.
How CertaRelay helps
- Map your existing packaging records to Maine's material types.
- Evaluate likely exemptions and document the basis.
- Monitor DEP's SO selection and calendar the registration window.
- Prepare Maine reports from the same packaging foundation used for other states.