Short answer: Maryland's Packaging and Paper Products Producer Responsibility Plans Act, signed in May 2025, requires producers of covered packaging and paper products to participate in an approved producer responsibility program. Final regulations are codified at COMAR 26.04.14, and Circular Action Alliance is the approved PRO and published a list of registered producers in July 2026.
What the law is
The Packaging and Paper Products Producer Responsibility Plans Act (SB 901, 2025 Regular Session) was signed May 13, 2025. The Maryland Department of the Environment (MDE) administers it.
Program facts
Current status, as published by MDE
- Proposed regulations were published February 6, 2026, and a Notice of Final Action was published May 15, 2026. The regulations are codified at COMAR 26.04.14.
- MDE has published a response to public comments and a Compliance Guide with FAQs for COMAR 26.04.14.
- Circular Action Alliance (CAA) is the approved producer responsibility organization.
- CAA released a report of registered producers and brands dated July 2026.
- MDE provides an Exempt or Excluded Producer Determination Request form.
CAA's official role
In Maryland, CAA serves as the approved PRO. Producers generally meet their obligations by registering and reporting through CAA, which develops the program plan and manages producer fees. Producers that are unsure of their status can use MDE's determination request process.
Producer identification
As in other states, Maryland identifies the responsible producer through a hierarchy that generally begins with the brand owner. MDE's Compliance Guide and FAQs explain how the definitions in COMAR 26.04.14 apply. If you sell into Maryland through distributors or retailers, evaluate your status rather than assuming the reseller is responsible.
Reporting preparation
Maryland reporting requires the same foundation as other programs: units supplied into the state, component-level packaging data, and mapping to the PRO's categories. Because Maryland's implementation began recently, confirm the current reporting format and deadlines in MDE's Compliance Guide and on CAA's Maryland pages before preparing a submission.
Current implementation status
Maryland moved quickly from enactment to final regulations. Producer registration through CAA is underway, and the law contemplates producer responsibility plans and program implementation later in the decade. Check MDE for current milestones.
CertaRelay recommendation
If you sell into Maryland and are not on CAA's registered producer list, determine your status now, either by registering or by documenting why you are exempt or excluded using MDE's process.
What your team should prepare
- Units supplied into Maryland by SKU.
- Component-level packaging data that can be mapped to CAA's categories.
- Brand ownership details for each product line.
- Your CAA registration status, or the basis for any exemption or exclusion.
How CertaRelay helps
- Screen your Maryland producer status and organize facts for MDE's determination process or counsel.
- Prepare Maryland reporting from your existing packaging foundation.
- Track MDE and CAA milestones as implementation progresses.