State guides

Packaging EPR laws by state.

Seven U.S. states have enacted packaging Extended Producer Responsibility laws. Here is how they compare, where each program stands, and what producers generally need to do.

Author: CertaRelayRequirements may change. Verify current obligations with the applicable agency, PRO or qualified counsel.

Short answer: California, Colorado, Oregon, Maine, Minnesota, Maryland and Washington have enacted packaging EPR laws. Oregon and Colorado are operating with producer fees. California and Maryland have final regulations. Minnesota, Washington and Maine are building their programs. Six states use Circular Action Alliance as the PRO; Maine uses a stewardship organization contracted by the state.

State-by-state comparison

Program status and deadlines change frequently; confirm with the official source before acting. This table is informational and not legal advice.
StateLaw / programGeneral statusPRO or administrative modelHigh-level producer actionOfficial source
CaliforniaSB 54, Plastic Pollution Prevention and Packaging Producer Responsibility Act (2022)Permanent regulations effective May 2026; PRO plan submitted October 2026 and under CalRecycle reviewPRO: Circular Action Alliance; CalRecycle oversightJoin the PRO plan, comply individually or apply for an exemption; register through PEPRSCalRecycle
ColoradoHB 22-1355, Producer Responsibility Program for Statewide Recycling Act (2022)Program plan approved 2025; participation required to sell since July 2025; dues from January 2026PRO: Circular Action Alliance; CDPHE oversightRegister with CAA, report supply and pay annual duesCDPHE
OregonSB 582, Recycling Modernization Act (2021)Operating; fees since July 2025; annual supply reports due May 31PRO: Circular Action Alliance; DEQ oversightRegister with CAA, report prior-year supply by May 31 and pay feesOregon DEQ
MaineStewardship Program for Packaging, 38 M.R.S. § 2146 (2021)Rules adopted; stewardship organization not yet selected; schedule being reassessedStewardship organization under contract with DEPPrepare data; register with the SO within 90 days once registration opensMaine DEP
MinnesotaPackaging Waste and Cost Reduction Act (2024)Phase 1: needs assessment; first stewardship plan expected 2027 to 2028PRO: Circular Action Alliance; MPCA oversightPrepare packaging data and follow PRO registration and plan milestonesMPCA
MarylandPackaging and Paper Products Producer Responsibility Plans Act (2025)Final regulations at COMAR 26.04.14 (2026); producer registration underwayPRO: Circular Action Alliance; MDE oversightRegister through CAA or document an exemption or exclusionMDE
WashingtonRecycling Reform Act, Chapter 70A.208 RCW (2025)Producer obligations begin 2026; needs assessment and rulemaking underwayPRO: Circular Action Alliance; Ecology oversightRegister with CAA; non-members cannot sell after March 2029Ecology

Why one product catalog can be treated differently in each state

It is natural to expect that a product reported in one state can be reported the same way in another. In practice, the same SKU can produce different results across programs for several reasons:

  • Producer definitions differ. Each law has its own hierarchy. A licensed brand or an imported product may be your obligation in one state and someone else's in another.
  • Scope differs. Washington focuses on residential packaging and paper. California's SB 54 covers single-use packaging and plastic single-use food service ware. Oregon includes food serviceware. Business-to-business exclusions vary.
  • Exemptions differ. Revenue and tonnage thresholds are not uniform, and some states phase thresholds in over time.
  • Material categories differ. Each program groups materials its own way. A multi-layer pouch or a plastic-coated paperboard carton may map to different categories.
  • Fees differ. Rates and eco-modulation rules are set per program, so the same packaging carries different costs.
  • Timelines differ. Data years, reporting deadlines and payment dates do not line up.

The practical answer is not to build seven separate datasets. It is to build one accurate, component-level packaging record and then apply each state's rules to it. That is the approach described in packaging data for EPR reporting, and it is how CertaRelay runs managed packaging EPR compliance.

State guides

Related resources

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