California and Maryland ushered in a number of Extended Producer Responsibility (EPR) obligations last week. Although packaging EPR laws in Oregon and Colorado have been operational for some time, recent milestones in California and Maryland will bring their programs into full swing this summer. While not yet fully implemented, Minnesota and Washington’s programs also hit recent milestones.
Producer Registration Deadlines
The first of these milestones requires producers to register with the Circular Action Alliance (CAA) in California and Maryland. Both states recently finalized regulations to implement their EPR laws for packaging, giving effect to statutory and regulatory deadlines.
In California, producers had until June 1, 2026, to either:
- Register with CAA and submit required supply data;
- Register with CalRecycle and apply to be an independent producer; or
- If claiming the small-producer exemption, register with CalRecycle and apply for the exemption.
In Maryland, the CAA must supply a list of its members to the Maryland Department of the Environment (MDE) by July 1, 2026. To meet that deadline, the CAA required producers who intend to comply with Maryland’s EPR law through the CAA’s program to register by June 1, 2026. Producers who choose to comply with the law independently, through an Individual Producer Responsibility Plan (IPP), must register with the MDE directly by July 1, 2026.
Producers in Washington must be members of a PRO (or an approved independent system) by July 1, 2026. Producers that plan to join the CAA will have to do so by June 30, 2026.
Producer Reporting Deadlines
Producer reporting (some for full annual reports, and some for interim reports) in California, Colorado, Maryland, Minnesota, Oregon, and Washington hit other major milestones on June 1. Annual and interim reports were due in those states. Specifically, producers in Oregon, Colorado, and California were required to submit 2025 Annual Supply Reports by June 1, 2026. These Annual Supply Reports require detailed information from each producer about the amount of covered packaging and paper products supplied into each state, broken down at the SKU or component level. This data is used to calculate EPR producer fees in future program years.
Producers in California were also required to submit two additional reports by June 1, 2026: a Baseline Producer Report to establish their 2023 baseline supply and packing data, and an Annual Source Reduction Report describing their 2025 plastic use and plastic reduction progress. Oregon producers could also file optional information on life cycle‑based, eco‑modulation bonus credits which can reduce future Oregon EPR fees, by June 1, 2026.
Producers in Minnesota, Maryland, and Washington were required to submit Interim Producer Reports by June 1, 2026, as well. These simplified reports only require high‑level 2025 data and use fewer material and format categories compared to full Annual Supply Reports.
Takeaway. The number of June 1, 2026, milestones significantly advanced EPR packaging programs nationwide. Producers throughout the U.S. should be up to speed, or coming up to speed, on their reporting obligations and solidifying mechanisms to track and report their packaging. This is a complex task since each state has slightly different requirements and rules.