As U.S. states continue to roll out Extended Producer Responsibility (EPR) laws for packaging, compliance deadlines are approaching fast. Today, seven states have active EPR frameworks — and each has its own timeline for registration, data reporting, fee obligations, and other requirements.
This Q1 2026 Global-Pak update highlights the important dates producers selling into these states need to know right now — and the steps your business should take to stay compliant, competitive, and ahead of regulatory risk.
Active U.S. State Packaging EPR Laws & Important Dates
California — SB 54 (Plastic Pollution Prevention & Packaging Producer Responsibility Act)
Under California’s SB 54, producers selling packaging and single-use plastic food service ware must join a Producer Responsibility Organization (PRO) and prepare to meet extensive compliance obligations.
Key Dates
- August 1, 2025: PRO registration opened
- September 5, 2025: Initial PRO registration phase deadline
- November 15, 2025: Baseline packaging data reporting (first reporting milestone)
- January 1, 2027: PRO fee obligations begin
- 2032: 100% recyclable/compostable packaging and 25% reduction in single-use plastics targets
What This Means
Producers selling packaging or single-use plastic food service ware into California must already be registered with the approved PRO and engaged in data classification and reporting. While fee payments do not begin until 2027, early data accuracy and material classification are critical to future compliance and cost management.
Colorado — Statewide Recycling Producer Responsibility Program
Colorado’s law focuses on ensuring every resident has access to recycling services.
Key Dates
- October 1, 2024: Producer registration deadline (passed)
- July 31, 2025: Data reporting deadline (passed)
- January 1, 2026: First producer fee payments to PRO
What This Means
Colorado producers should already be registered and have completed required reporting. Fee payments are now active as of 2026, making ongoing data accuracy and internal compliance processes essential.
Maine — Stewardship Program for Packaging Materials
Maine was the first U.S. state to adopt a packaging EPR law.
Key Dates
- May 31, 2026: Producer registration and reporting deadline for 2025 packaging data
- 2027: Reporting of 2026 packaging data and initial producer payment obligations
What This Means
Producers must prepare to register with the approved stewardship organization and submit 2025 packaging data by May 31, 2026. While most producer payments occur later, Maine requires early data readiness and reporting discipline beginning in 2026.
Maryland — Packaging & Paper Products Producer Responsibility Plans Act
Key Dates
- 2026: Expected start of PRO registration
- July 1, 2029 (tentative): Potential first producer reporting obligations
What This Means
Maryland’s program is in the early stages. Producers should begin tracking packaging data now and monitoring rulemaking developments. Early preparation offers strategic advantages ahead of future reporting and plan submission requirements.
Minnesota — Packaging Waste & Cost Reduction Act
Minnesota’s new EPR law continues implementation.
Key Dates
- July 1, 2025: Producer registration deadline
- February 1, 2029 (tentative): Fee obligations scheduled to begin
What This Means
Minnesota producers must be registered but have several years before direct fee impacts begin. This period should be used to build data systems, assess packaging design, and plan long-term sustainability and cost strategies.
Oregon — Plastic Pollution & Recycling Modernization Act
Oregon’s EPR law is already in effect, and implementation timelines continue rolling forward.
Key Dates
- March 31, 2025: Deadline for reporting 2024 packaging data (passed)
- July 1, 2025: Producer fee payments began
- Ongoing: Annual reporting and fee obligations
What This Means
Oregon’s program is fully active. Producers should already be registered with a PRO, reporting packaging supply data, and paying fees. Ongoing compliance requires accurate annual data reporting and internal planning for eco-modulated fees.
Washington — Packaging EPR Law (SB 5284)
Washington’s law establishes packaging EPR, but implementation milestones remain in early stages.
Key Dates
- January 1, 2026: PRO appointment and selection process begins
- July 1, 2026: Producer registration / PRO membership deadline
What This Means
Producers must monitor PRO approvals closely and be prepared to join a PRO by mid-2026. Early engagement will ease future reporting and fee compliance as Washington’s program matures.
How Global-Pak Tracks These Deadlines
Global-Pak’s Quarterly Regulatory Update Program continually monitors:
- Official state agency announcements and regulatory schedules
- Recyclability classifications and covered material changes
- Producer Responsibility Organization (PRO) actions and approval timelines
- Reporting and fee obligation deadlines and model changes
- Guidance from industry associations and legal experts
Updates are published here on global-pak.com/blog and highlighted in our quarterly market update emails.
Why These Dates Matter to Your Business
Meeting these compliance deadlines directly impacts:
Market access: Some states restrict sales of non-registered packaging suppliers.
Cost forecasting: Early awareness of fee timelines improves budgeting.
Design planning: Advance knowledge of recyclability thresholds informs material choices.
Risk mitigation: Missing reporting deadlines can trigger penalties and enforcement actions.
Final Recommendations for Q1 2026
Confirm your state footprint: Map all states where your packaging is sold.
Prioritize data readiness: Ensure packaging weights, resin types, and recycled content data are organized.
Track upcoming deadlines: Add each state’s key compliance dates into your internal regulatory calendar.
Keep up with Global-Pak’s quarterly updates: Gain insights on changing requirements delivered quarterly.
This information reflects our understanding of current packaging EPR requirements based on guidance available at the time of writing. EPR laws and implementation timelines continue to evolve, and requirements may change as additional regulations and agency guidance are issued. This summary is provided for informational purposes only, and no liability is assumed for inaccuracies or subsequent changes.