2025 is a big year for extended producer responsibility (a.k.a. EPR) for packaging in the United States (US). If you are not familiar with the concept, EPR for packaging laws are designed to shift the burden of funding collection, recycling, and end-of-life of packaging and packaging-related materials from municipalities and tax payers to the producers of the materials themselves.

Although this approach, also known as a packaging tax, is relatively new in the US, over 60+ nations have implemented similar programs to hold producers of packaging accountable for the entire lifecycle of their products.

Another component to EPR is eco-modulation, designed to offer producers rebates and incentives if they take compliance a step further by optimizing designs for sustainability (PCR content, biomaterials, etc.), using tools like life cycle assessments to measure impacts, and more. 

To read more on the EPR for packaging programs that have passed and are currently being implemented in the US—in Oregon, California, Maine, Colorado, and Minnesota—check out our research article here. This blog will focus on key dates to be aware of for EPR in packaging programs across the US, so let’s get started! 

Oregon

The state of Oregon enacted their EPR for packaging program in August of 2021, dubbed the Plastic Pollution and Recycling Modernization Act (SB 582). The three types of materials covered in this program are packaging, food service ware, and printing and writing paper, defined in a Summary of Producer Obligations & Definitions document posted by the Oregon Department of Environmental Quality (DEQ).

Similar to other EPR for packaging programs in the US, the Department of Environmental Quality chose the Circular Action Alliance (CAA) to serve as the program’s producer responsibility organization (PRO)—a non-profit that works to register producers, collect and allocate fees, set eco-modulation requirements, and more. 

Key Dates for Oregon's SB 582 in 2025

March 31, 2025:

Reporting deadline for producers—meaning producers must submit a report of packaging materials used in 2024 in the state of Oregon to the CAA/DEQ

On or before July 1, 2025:

EPR program set to begin

September 1, 2025:

PROs (CAA) remit first administrative fees to DEQ

Fall 2025:

Producers can submit voluntary life cycle assessments of up to 10 BOMs (Bill of Materials) to receive up to $20,000 USD in eco-modulation bonuses—to be paid in 2026

Stay tuned for updates and other key dates here.

Colorado

Colorado passed their EPR for packaging law on June 3rd of 2022, called the Producer Responsibility Program for Statewide Recycling Act (HB 22-1355). Materials covered include consumer-facing packaging materials and paper products, including packaging made of all materials; you can read the specifications here.

Similar to Oregon, Colorado’s Department of Public Health & Environment (CDPHE) selected the Circular Action Alliance (CAA) as the sole PRO to lead the state’s program, announced in May of 2023.

Key Dates for Colorado's EPR program in 2025

February 1–3, 2025:

CAA submitted draft program plan proposal to CDPHE

July 31, 2025:

Preliminary deadline for data reporting of 2024 packaging data to the CAA

The program is set to begin early 2026—stay up to date with the program here.

California

The state of California passed their EPR for packaging program in June 2022, named the Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54). The covered materials under SB 54 include single-use packaging and plastic single-use food service ware (both commercial and residential)—you can see the full list in the Covered Material Categories List here.

Like Oregon and Colorado, the state of California (CalRecycle) selected the CAA as the sole PRO for SB 54 in early January 2024.

Key Dates for California's SB 54 in 2025

January 1, 2025:

Deadline for producers of EPS (styrofoam) food service in California to show 25% recycling rates to CalRecycle

August 2025:

Preliminary deadline for data reporting of 2024 packaging data to the CAA

It is expected that the CAA will submit a program plan mid 2026, followed by the SB 54 Advisory Board reviewing the plan and a program start date of January 1, 2027. Stay up to date with program changes and deadlines here.

*UPDATE: After missing a March 8th deadline to finalize SB 54, Packaging Dive reports that Governor Gavin Newsom is calling for CalRecycle to restart the SB 54 process to ensure that the laws are implemented fairly and don't create hardships for consumers and smaller organizations.

Maine

Although the implementation timeline for Maine has been longer than other states, Maine was the first state in the US to pass an EPR for packaging law, called the Stewardship Program for Packaging (S2145). The covered materials for Maine’s program are not fully laid out yet, but what we know so far is a “consumer packaging material” includes “any material used to contain, protect, or present a product at the point of sale for.”

Maine has not yet released a request for proposal (RFP) for Stewardship Organizations (equivalent to PRO), but the CAA highlights that they plan to respond to the RFP—expanding its reach to all five EPR for packaging programs in the United States.

Key Dates for Maine's EPR program in 2025

September 2025:

Maine’s Department of Environmental Protection (DEP) plans to release an RFP for Stewardship Organizations (equivalent to PRO)—which CAA plans to submit a proposal for. 

This is the only key date for Maine’s EPR program in 2025. In 2026, the CAA notes that the DEP plans to contract a Stewardship Organization (SO) by April 2026, followed by producers registering with the SO and reporting 2025 packaging data by May 2026, and a program kick off (distribution of fees to municipalities) set for October 2027. 

Stay up to date with key program changes and dates here.

Minnesota

The state of Minnesota was the latest state to pass an EPR for packaging law, with the Packaging Waste and Cost Reduction Act (HF 3911) being signed into law in May of 2024. The latest EPR for packaging law in the US covers “packaging and packaging components, food packaging, and paper products” that are sold, distributed, or used to package a product sold into Minnesota. You can read the full covered materials list here.

In recent news, the Minnesota Pollution Control Agency (MPCA) selected the CAA to implement the state's EPR program on February 18, 2025. This means that the CAA is now the PRO for four states with EPR for packaging in the US, with plans to submit a proposal for Maine this September.

Key Dates for Minnesota's EPR program in 2025

February 18, 2025:

MPCA officially appoints CAA as the PRO for Minnesota

July 1, 2025:

Registration deadline for producers

These two dates are the only two key dates listed for Minnesota’s EPR for packaging program in 2025. Other notable dates in the future include an initial needs assessment planned to be finished by year end 2026 and a PRO stewardship plan due date set for October 1, 2028. However, if you are a producer, the date to focus on is July 1, 2025! Stay up to date with program changes and key deadlines here.

Obtain Eco-Modulated Fees with LCA

All five EPR for packaging programs in the US have made mention of including eco-modulation (eco-modulated fees) programs alongside other compliance measures—reporting, fees based on tons of material, etc.

While these programs are still in development, the Oregon DEQ and CAA have been transparent about their plans to include life cycle assessments (LCAs) as part of their eco-modulation and fee reduction processes, as reported by Packaging Dive.

The plans include mandatory LCAs for the top 25 producers on 1% of their products sold / distributed into the state every two years and the opportunity for smaller producers to submit voluntary LCAs by fall of 2025 to receive up to $20,000 USD in bonuses—read more on the plans to implement LCA into Oregon’s EPR program here. 

Interested in securing a $20,000 USD eco-modulation bonus but your organization lacks LCA experience? Check out our Certificate of Sustainable Packaging (CSP) program that includes a module training you how to conduct an LCA on your primary, secondary, and tertiary packaging systems using a software specifically designed for LCAs for packaging systems.