EPR Reporting Deadlines Put Packaging Compliance into Action

Extended Producer Responsibility (EPR) regulations for packaging have moved from planning to implementation. In 2026, several state programs put new registration and reporting obligations into effect, adding immediate compliance requirements to an already complex multi-state regulatory landscape.

To date, seven states have enacted EPR legislation: California, Colorado, Maine, Maryland, Minnesota, Oregon, and Washington. As the programs move into implementation, producers face recurring reporting, registration and compliance obligations across multiple markets.

Reporting Requirements Move EPR Into Practice

Six of the seven states enacted producer reporting deadlines in May 2026. This May 31 deadline marked one of the first major operational milestones for packaging EPR compliance in the U.S., requiring producers to submit packaging data tied to materials placed into state markets as follows:

• California: Producers submit an annual supply report and an annual source reduction report covering 2025 data
• Colorado, Oregon: Producers submit annual supply reports covering 2025 data to inform 2027 programs
• Maryland, Minnesota, Washington: Producers submit a simplified pre-program supply report covering 2025 data

Across California, Colorado, Maryland, Minnesota, Oregon and Washington the Circular Action Alliance (CAA), the state-approved PRO, assisted producers moving into active reporting. CAA manages registration, reporting and compliance administration on behalf of participating producers across the six state programs. Maine remains the exception, as the state has not yet established a reporting deadline while its producer responsibility organization (PRO) selection process is still underway.

Even with growing coordination through CAA, compliance requirements remain fragmented across the states. Producers operating across multiple markets still face different definitions, reporting expectations and program timelines depending on where their products are sold.

State Programs Expand and Evolve

Reporting deadlines marked the start of active compliance, but many state programs are still in the early stages of broader implementation. Recent updates from several EPR states have increased discussion around state programs.

California

California published final SB 54 rules in May 2026 for execution with phased targets along the way. By 2032, producers must:

• Reduce the use of covered materials by 25%
• Ensure recycling rates of 65%
• Ensure 100% recyclability or compostability for all single-use packaging and service ware

California also established a June 1, 2026, deadline for companies to register with the CAA PRO or as an independent producer with CalRecycle. The same deadline applied for any small producer seeking an exemption. For California-specific guidance, review this producer guidance published by CalRecycle and the guide to illustrative fees published by CAA.

Maine

Maine finalized program rules in late 2024 before amending portions of its legislation to further clarify producer definitions, exemptions and post-consumer recycled (PCR) material requirements. Those revisions brought greater alignment with other state packaging EPR frameworks already in operation.

Washington

Washington selected CAA as its approved PRO in 2026 following the passage of the Recycling Reform Act in 2025.

Ongoing Regulation

States across the U.S. continue to evaluate EPR legislation. New York’s EPR bill could have been put to a vote this year, but the legislative session adjourned and the bill stalled. Ten other states, from Wisconsin to Hawaii, have considered EPR. New programs are expected to emerge in the next five years.

But signing EPR into law does not end its evolution. California and other states with established EPR programs, including Colorado and Oregon, are navigating legal challenges to EPR laws that may impact rules going forward. Maintaining visibility into the resulting EPR changes will be key to navigating ongoing compliance. Keeping pace with that regulatory momentum starts with packaging decisions made today.

Turn Packaging Design into Competitive Advantage

EPR creates a stronger connection between packaging design decisions and long-term compliance costs. Fee structures tied to material type, recyclability, PCR content and other packaging design characteristics are pushing producers to re-evaluate packaging choices.

Designing for circularity is now a competitive advantage as more states move toward packaging EPR requirements. Producers that improve recyclability, incorporate PCR content and align packaging choices with established EPR frameworks may be better positioned to maintain market access and minimize compliance fees. Finding a good source for PCR and choosing materials that recycle well can help lower overall eco-modulated fees and improve a company’s ability to compete in the market space.

As packaging EPR programs expand across the U.S., producers need partners that can help evaluate packaging decisions for both performance and compliance. M. Holland supports customers navigating these changes with a variety of PCR material options, material selection guidance and testing services. To learn more, visit our Sustainability market page or read How to Prepare for Evolving EPR Regulations.