Guide to Packaging EPR in the United States

In recent years, several states in the United States have implemented Extended Producer Responsibility (EPR) regulations for packaging products. So far as I know, these are the states that have already approved such regulations:

• California
• Colorado
• Maine
• Maryland
• Minnesota
• Oregon
• Washington

This guide aims to list EPR requirements in the above-listed states, such as covered products, responsible persons, thresholds, fees, producer responsibility organizations (PRO), and more.

Which US state has packaging EPR requirements?

According to the Circular Action Alliance (CAA) website, a US non-profit PRO that focuses on implementing EPR laws for packaging and paper, there are seven US states that have packaging EPR laws.

I found the same information on other websites, such as:

• Ecopackables.com
• Proskauer.com
• Amcor.com

I list these states in the table below. Also, according to Ecopackables.com, the following states are working on their own packaging EPR laws:

• Illinois
• Massachusetts
• New Hampshire
• New Jersey
• New York
• Rhode Island
• Virginia
• Wisconsin

Overview

US State	Regulation	Scope	PRO	Date*
California	Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54) (Link)	a. Single-use packaging b. Plastic single-use food service ware	Circular Action Alliance	1 January 2027
Colorado	Producer Responsibility Program (Link)	Packaging and paper products	Circular Action Alliance	July 2025
Maine	Stewardship Program for Packaging, 38 M.R.S. § 2146 (Link)	Packaging made of glass, metal, paper, plastic, and other materials	None yet, according to what I found	None found
Maryland	Environment – Statewide Recycling Needs Assessment and Producer Responsibility for Packaging Materials Act (Link)	Packaging and paper products	Circular Action Alliance	31 May 2026
Minnesota	Packaging Waste and Cost Reduction Act (Link)	Packaging	Circular Action Alliance	1 July 2025
Oregon	Plastic Pollution and Recycling Modernization Act (Link)	Residential and commercial packaging, paper, and food serviceware	Circular Action Alliance	1 July 2025
Washington	Recycling Reform Act (Link)	Residential packaging and paper products	Circular Action Alliance	1 July 2026

*Note: We listed the date from which, according to what we found, producers must join a PRO and/or start to participate in the responsibility programs.

California

What packaging is covered?

The Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54) covers single-use packaging and plastic single-use food service ware.

Who is responsible?

The producer, which is defined as the manufacturer; the brand owner, if there is no manufacturer in the state; or the seller/distributor (if there is no manufacturer or brand owner in the state).

Thresholds

Producers that had gross sales under USD 1,000,000 in California in recent calendar years are exempt.

Registration requirements

You must register on the Circular Action Alliance’s website by filling in the online form under the “Producer Registration” page. Once you register, you can comply with the reporting requirements and pay the due fee.

I understand that you must register by 1 January 2027.

Fees

The fees depend on several elements, including weight and materials of the packaging. You can find examples and illustrative fees on the Circular Action Alliance’s website.

Producer responsibility organization

Circular Action Alliance.

When does packaging EPR apply in California?

The Bill was approved on 30 June 2022. I understand that producers must join a PRO by 1 January 2027 in order to keep selling or distributing covered materials.

However, some of the Act’s requirements are already in force, as I found that producers of expanded polystyrene food service ware should not import or sell expanded polystyrene food service ware unless they can demonstrate that the products meet a recycling rate of at least 25%.

Colorado

What packaging is covered?

The Producer Responsibility Program covers packaging and paper products. According to the Act, this includes packaging made of:

• Paper
• Plastc
• Glass
• Metal
• Cartons
• Flexible foam
• Rigid materials

Who is responsible?

The producer, which is defined as the manufacturer, brand owner, seller, or distributor.

Thresholds

Companies that have less than USD 5,000,000 gross total revenue in the prior calendar year are exempt.

Registration requirements

You must head to the Circular Action Alliance’s website and complete the application form found on the “Producer Registration” page to set up your account. Once you sign up, you can submit required reports and handle fee payments.

Fees

The Colorado Producer Dues Schedule is available on the Circular Action Alliance website. The fees depend on the weight and materials of the packaging, such as:

• Paper
• Glass
• Metal
• Plastic
• Wood

Producer responsibility organization

Circular Action Alliance.

When does packaging EPR apply in Colorado?

The Governor of Colorado signed the Producer Responsibility Program for Statewide Recycling Act into law in 2022. Since July 2025, a producer cannot sell covered material unless they participate in the program.

Maine

What packaging is covered?

The Stewardship Program for Packaging mentions packaging made in the following materials:

• Glass
• Metal
• Paper
• PET (#1)
• HDPE (#2)
• PP (#5)

Who is responsible?

The producer, defined as the manufacturer, brand owner, importer of record, or distributor.

Thresholds

Producers with less than USD 2,000,000 in gross annual revenues during the first three years of agreement with their stewardship organization are exempt. The threshold increases to USD 5,000,000 in the fourth year.

Note: I understand that “stewardship organization” is how “producer responsibility organizations” are called in Maine.

Registration requirements

As far as I understand, it is still not possible to register, as no stewardship organization has been appointed yet.

The Circular Action Alliance, which acts as PRO in the other states that have EPR laws, wrote on its website that they have decided not to submit a bid in response to Maine’s RFP for Environmental Packaging Stewardship Services, which was released on 15 June 2026.

Fees

I found that a producer must pay fees to the stewardship organization of its choice based on the packaging material and weight.

Producer responsibility organization

In Maine, the term “stewardship organization” is used. However, so far there is no established organization, according to what I found.

When does packaging EPR apply in Maine?

The Maine’s Stewardship Program for Packaging was established in July 2021. I understand that producers must register within 90 days of when a stewardship organization makes the registration mechanism available.

Maryland

What packaging is covered?

The Environment – Statewide Recycling Needs Assessment and Producer Responsibility for Packaging Materials Act covers packaging and paper products, including plastic, metal, and glass products, for example.

Who is responsible?

The producers are responsible for their own packaging. A producer is defined as the manufacturer, brand owner, importer, or distributor.

Thresholds

I found that the threshold to be considered a producer is to have earned global gross revenues of at least USD 2,000,000 or have introduced at least one ton of covered material in the state, in the previous year.

Registration requirements

Producers must register on the Circular Action Alliance’s website by May 2026. Once they are registered, they can start to report the data concerning their packaging.

Fees

I found that the law ​requires producers of packaging to pay fees aimed at helping to cover the recycling cost. However, I could not find details on the specific fees, besides a registration fee.

Producer responsibility organization

Circular Action Alliance.

When does packaging EPR apply in Maryland?

The Governor of Maryland signed the Environment – Statewide Recycling Needs Assessment and Producer Responsibility for Packaging Materials Act into law in May 2023.

However, I understand that producers needed to register with the Circular Action Alliance by 31 May 2026 and start to pay fees by 1 July 2028.

Also, according to the Circular Action Alliance’s website, a Producer Responsibility Plan must be prepared by the Alliance – or by independent producers that did not join the PRO – by 1 July 2028.

Minnesota

What packaging is covered?

The Packaging Waste and Cost Reduction Act covers packaging, defined as a container that provides a means of protecting or handling a product.

Who is responsible?

The producer, which is defined as the manufacturer (if the product is sold under its brand or with no brand), the brand owner, the importer of record, or the distributor

Thresholds

I could not find any thresholds under which producers are not required to comply with EPR requirements.

Registration requirements

You must register via the Circular Action Alliance’s website by filling in the required form.

Fees

I found that PROs must collect an annual fee from producers based on the total amount of covered packaging that the producer introduced in the prior year, and the type of material introduced.

Producer responsibility organization

Circular Action Alliance.

When does packaging EPR apply in Minnesota?

Producers must become a member of Circular Action Alliance, or another PRO, if any, by 1 July 2025. However, I understand that the first fees are due in 2029.

Oregon

What packaging is covered?

I found that the Plastic Pollution and Recycling Modernization Act covers residential and commercial packaging, paper, and food serviceware.

Who is responsible?

Producers, which are defined as the manufacturer, the brand owner (if different than the manufacturer), the importer of record, or the distributor.

Thresholds

I found that the threshold is to have gross revenues of more than USD 5,000,000 in Oregon or have sold more than one metric ton of covered products in the state, in the most recent calendar year.

Registration requirements

Also in this case, you must complete the registration in the Circular Action Alliance’s website. Once your company is registered, you can start to fill in the required reports, and settle the necessary fees.

Fees

You can find the Oregon Producer Fee Schedule on the Circular Action Alliance’s website. The fees vary based on the quantity of introduced material and on the type of material, such as:

• Paper
• Glass
• Ceramics
• Metals
• Plastics

Producer responsibility organization

Circular Action Alliance.

When does packaging EPR apply in Oregon?

Producers must become a member of a PRO by 1 July 2025.

Washington

What packaging is covered?

I found that the Reform Act covers residential packaging and paper products.

Who is responsible?

The producers are responsible. In general, they are defined as the brand owners of consumer products sold in the state. However, in some cases the producers may be the manufacturers, brand licensee, importer of record, or distributor.

Thresholds

I found that the minimum threshold is set to USD 5,000,000 of global revenues or the introduction of a minimum of one ton of covered material in the state, in the most recent fiscal year.

Registration requirements

You must register your company on the registration page published on the Circular Action Alliance’s website.

Fees

The PRO must charge each member a fee that is based on unit-based, weight-based, volume-based, or sales-based. The important thing is that the fee must be sufficient to pay the costs connected to collecting and processing the waste.

Producer responsibility organization

Circular Action Alliance.

When does packaging EPR apply in Washington?

The Washington’s Recycling Reform Act passed in 2025. Producers must become a member of a PRO by 1 July 2026.