EPR for Packaging Dates in 2026: United States

2025 marks a landmark year for Extended Producer Responsibility (EPR) for packaging in the United States—with Oregon’s SB 582 becoming the first program to be operational in the United States this July. 

Alongside Oregon, six other states—marked in green on the map above—are also implementing their own EPR for packaging programs with different timelines, requirements, and more. If you are new to EPR for packaging, check out this article and continue reading from here.

While EPR for packaging is relatively new in the United States, over 60 nations around the world have launched similar programs to ensure producers and brands are responsible for the entire lifecycle of their packaging solutions—from cradle to grave and everything in between. This responsibility is mandated through fees paid by material weight and composition that are invested in recycling infrastructure and improvements, increased reporting requirements, and ecomodulation programs to incentivize producers to minimize impacts at the packaging design level. 

If you are new to EPR for packaging and having some “compliance anxiety,” you are not alone! In an effort to ease some of that anxiety, the remainder of this article will cover the EPR for packaging dates you need to know in 2026 for Oregon, Colorado, California, Maine, Minnesota, Maryland, and Washington. 

Oregon

As mentioned above, Oregon’s SB 582—Plastic Pollution and Recycling Modernization Act—is the first operational EPR for packaging program in the United States. The reporting deadline for 2024 packaging data was March 31 of this year and the program’s kick-off date was July 1, 2025.

SB 582 covers packaging, food serviceware, and printing and writing paper sold in the state of Oregon—more information on covered materials can be found in this Summary of Producer Obligations & Definitions document provided by Oregon’s Department of Environmental Quality (DEQ). 

Like other EPR programs in the United States, Oregon’s DEQ chose the Circular Action Alliance (CAA) to serve as the sole Producer Responsibility Organization (PRO) for SB 582. If you aren’t familiar with PROs, think of them as a non-profit filled with industry experts that help producers register, submit fees and reports, set up ecomodulation programs, and ensure the program is functioning as defined in law.

Key Dates for Oregon’s SB 582 in 2026

Spring 2026:

Based on the reporting deadline for 2025 (March 31), we expect a similar deadline for reporting of 2025-related packaging data. Stay tuned for more updates on this front.

May 2026:

The proposed deadline for ecomodulation bonuses B and C—read more on the programs here. 

Summer 2026:

In this period, producers who submitted reports for Ecomodulation Bonus A in August 2025 will receive fee reductions towards 2025 EPR fees related to assessed SKUs.

As of July 2026, there are no dates on the CAA site for Oregon’s EPR program for 2026. Stay tuned for updates and other key dates here. 

Colorado

Colorado is the next state in line to start implementing their EPR for packaging program—the Producer Responsibility Program for Statewide Recycling Act. Materials covered under Colorado’s EPR program include “consumer-facing” packaging materials and paper products, regardless of packaging substrate—you can read more on covered materials and program layout here. 

Like Oregon’s SB 582, Colorado’s Department of Public Health & Environment (CDPHE) appointed the CAA as the PRO to carry out the implementation and management of their EPR program. 

Key Dates for Colorado’s EPR program in 2026

January 1, 2026:

The deadline for producers to remit dues to the CAA. In other words, this is the date in which producers have to pay fees based on 2024 packaging data submitted by July 31, 2025.

Early 2026:

According to the CAA website, early 2026 marks the period in which the program will begin—similar to Oregon’s kick-off date on July 1, 2025.

June 30, 2026: 

This date marks when the CAA will remit the first administrative dues to the CDPHE. In other words, the CAA will pay the CDPHE administrative fees to the CDPHE, which are collected from fees paid by producers. These payments will help CDPHE run the program and cover administrative costs and oversight fees. 

As of now, these are the only dates available on the CAA page for Colorado for 2026. It is important to note that the CAA and CDPHE might release more information regarding ecomodulation in the coming months, which may include 2026 submission deadlines. The Packaging School team will work to update this article when more information is released. 

Read more on the implementation timeline and Colorado’s EPR program here. 

California

California, the nation's largest economy and the fourth largest in the world, has had a relatively long road to EPR implementation with their Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54). 

Initially passed in June 2022, the program failed to meet a March 2025 finalization deadline and was sent back to the drawing board due to concerns around costs for families, small businesses, and producers. This is a common debate in the EPR space; if you want to read more on it check out our research article here. 

Like Oregon and Colorado, California’s CalRecycle selected the CAA to serve the PRO for SB 54—a program that covers residential and commercial single-use packaging and food serviceware made of single-use plastic and requires the PRO to remit $500 million USD each year in producer fees starting in 2027.

Key Dates for California’s EPR program in 2026

Mid 2026:

By midway through the year in 2026, the CAA expects to submit an updated program plan for SB 54, following the delay in March of this year. In this same period, CalRecycle and the SB 54 advisory board will review the CAA plan and offer comments. 

As of July 2025, this is the only SB 54 date listed on the CAA site for California. To see deadlines and dates for 2027, check out the rest of the timeline here. 

With CAA involvement in California’s program, it is possible that California’s SB 54 will also contain an ecomodulation program—potentially similar to Oregon’s. 

Maine

Maine was the first state in the country to pass an EPR for packaging law—with their LD 1541 passing in July of 2021. Despite being the first, Maine has had a long road to EPR implementation, planning to release a RFP for a stewardship organization (SO) and program plan development in September of this year. 

Despite Maine’s program plan not being developed yet, the CAA notes they plan to respond to the RFP that will be released in September 2025 and that the program will likely cover both packaging material that is already readily recyclable in the state and materials that are not. 

Additionally, unlike every other EPR for packaging program in the United States, Maine’s Department of Environmental Protection (DEP) decided to use the term Stewardship Organization (SO) instead of Producer Responsibility Organization (PRO). Despite the nomenclature, SOs and PROs hold the same functions in EPR for packaging programs. 

Key Dates for Maine’s EPR program in 2026

April 2026:

In this period, Maine’s DEP will select an SO based on SOs that respond to the RFP in September 2025. As we mentioned above, the CAA is planning to respond to this RFP to further expand their influence on EPR for packaging policy across the United States.

May 2026:

Following the selection of an SO to manage LD 1541, producers defined under the program plan will have to register with the SO and report 2025 packaging data. 

September 2026:

Months after producers register with the SO, they will be required to pay startup fees to the SO. This means producers will have to pay fees based on 2025 packaging data (by material and weight) to the chosen SO. 

These are the only dates available for Maine’s EPR program in 2026. To see dates beyond 2026, check out the fully available timeline here. 

Minnesota

In May of 2024, Minnesota became the fifth state to pass an EPR for packaging law with the signing of the Packaging Waste and Cost Reduction Act (HF 3911). Materials covered under HF 3911 include packaging, packaging components, food packaging, and paper-related products sold into the market in Minnesota—see more on covered materials here. 

Following the likes of Oregon, California, and Colorado, Minnesota’s Pollution Control Agency (MPCA) chose the CAA to serve as the PRO for HF 3911 in February of this year. Following this announcement, producers in the state had to register with the CAA by July 1 of this year.

Minnesota’s HF 3911 is unique compared to other EPR for packaging programs in the US as producers will not be required to cover all the costs related to services for collecting, processing, and recycling covered materials. By 2029, producers must cover 50% of net costs through fees paid which will build up to no less than 90% by 2031 and onward. 

Like Maine, Minnesota has decided to take the long road to EPR implementation with the program not starting until early 2029, but there is still a key date to be aware of in 2026. 

Key Dates for Minnesota’s EPR program in 2026

December 31, 2026:

By the end of next year, the MPCA will release an initial needs assessment to collect and analyze information about “packaging and paper product introduction, use and reuse, and management in Minnesota that will inform the development of the EPR program statewide” (MPCA). According to the MPCA site, the application deadline for third parties to assist in this assessment was April 15, 2025.

As of July 2025, this is the only date for 2026 related to Minnesota’s EPR program—see the full implementation timeline here. 

Maryland

In May of this year, Maryland became the sixth state to pass an EPR for packaging law with the singing of SB 901—Packaging and Paper Products - Producer Responsibility Plans Act. SB 901 will cover a wide array of packaging and paper products, including beverage and food packaging. 

Similar to Maine and Minnesota, Maryland’s road to an EPR for packaging bill was by no means simple. In 2023, Governor Wes Moore signed an EPR study bill—the Statewide Recycling Needs Assessment and Producer Responsibility for Packaging Materials Act (SB 0222)—into law. Following the passing of SB 0222, Maryland’s Department of the Environment (MDE) worked with a number of third-party consulting groups to complete a needs assessment of Maryland’s waste management infrastructure and gaps and opportunities that could be improved through an EPR program. 

While Minnesota baked a needs assessment requirement into the EPR law itself, Maryland took a slightly different approach by conducting the needs assessment before passing SB 901. Additionally, the MDE selected the CAA to serve as the PRO for the program and to serve on the State Producer Advisory Council in October of 2023. 

Key Dates for Maryland’s EPR program in 2026

July 1, 2026: 

By this date, an approved PRO will file a registration form with the MDE; this form will include producers who are compliant under SB 901 and a list of covered materials. This date also marks when producers can work to create and manage their own collection programs to collect and manage their own covered materials—aside from joining a PRO.

As of July 2025, this is the only date in 2026 related to Maryland’s EPR for packaging program. To see important dates in 2027, 2028, and onward, check out this article by Packaging Dive. 

Washington

Days after Maryland became the sixth state to pass an EPR for packaging law, Washington became the seventh with the passing of the Recycling Reform Act—SB 5284. SB 5284 defines “packaging” as “various materials, including single-use items that facilitate food and beverage consumption.” Read more on the text summary here. 

When we wrote on the introduction of SB 5284, one of the key goals of the program was to expand access to curbside recycling services across the state—with only 58% of jurisdictions in the state having access and eleven counties having no access at all. We also learned that SB 5284 is the seventh EPR program to pass in Washington, with other programs covering product categories like electronic waste, light bulbs with mercury, solar panels, paint, and more.

The program will be managed by the Washington Department of Ecology—who is set to select a PRO by March 1, 2026. Let’s explore the other notable dates for SB 5284 in 2026. It is not determined if the CAA will file to be a PRO in Washington, but with their activity in the six other states, it should certainly be expected.

Key Dates for Washington’s EPR program in 2026

January 1, 2026:

By this date, producers in the state will appoint one or more PROs to help manage the program and work alongside the Department of Ecology. This date also marks when the Department of Ecology will appoint an EPR advisory council to help shape the development of SB 5284. 

January 31, 2026:

This date marks when the Department of Ecology will manage registration of service providers in the state to help carry out EPR for packaging objectives. 

March 1, 2026:

By this date, the PRO(s) selected by producers will register with the Department of Ecology. 

July 1, 2026:

By this date, producers compliant under SB 5284 must be registered with a PRO.

September 1, 2026:

Following producers joining a PRO by July 1, the PRO must submit a “one-time payment” to the Department of Ecology on September 1 to assist with administrative costs and oversight practices. 

October 1, 2026:

This date marks the deadline for the Department of Ecology to develop and release an initial statewide collection list. 

December 31, 2026: 

By the end of 2026, the Department of Ecology will complete a statewide needs assessment to understand Washington’s recycling infrastructure and see how SB 5284 will help fill in the gaps.

As of July 2025, these are the only dates available related to Washington’s EPR for packaging program in 2026—see the full proposed implementation timeline here. 

Read more on EPR for Packaging

With seven states in the US implementing EPR for packaging laws at different stages and 60+ programs around the world, The Packaging School team has been following this space closely and writing a number of research articles on the topic. 

Dive into all of our EPR for packaging content in our EPR index here.