Extended Producer Responsibility (EPR) laws make the producers of packaging pay for its end-of-life collection and recycling. Seven U.S. states have enacted packaging EPR laws, covering roughly one in five Americans. This page compares EPR laws by state, side by side and on your choice of states: the governing statute, the PRO, when fees begin, which data years you report, the de minimis exemption, covered scope, key exemptions, eco-modulation, and the maximum penalty in each state. For pending bills and weekly updates, see the EPR Atlas hub.
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Pick the states you sell into and see where their programs differ on when fees start, which data years you report, who is exempt and for what, how eco-modulation works, and what non-compliance costs. Every cell is generated from the same data the state pages use and cites its provision. Toggle states and categories, hide the rows where the shown states agree, or download the view as CSV.
| Field | OROregonFees live | COColoradoFees live | CACaliforniaEarly fee invoiced | MEMainePre-fee | MNMinnesotaPre-fee | MDMarylandPre-fee | WAWashingtonEarly fee published |
|---|---|---|---|---|---|---|---|
| StatuteGoverning law and year | SB 582 - Plastic Pollution & Recycling Modernization Act (2021) Source: ORS 459A.860 to 459A.975 | HB 22-1355 - Producer Responsibility Program for Statewide Recycling (2022) | SB 54 - Plastic Pollution Prevention & Packaging Producer Responsibility Act (2022) Source: PRC 42040 et seq. (SB 54) | LD 1541 (2021) / LD 1423 (signed Jun 2025) Source: 38 MRSA 2146 | HF 3911 - Packaging Waste and Cost Reduction Act (2024) | SB 901 (Ch. 431 of 2025) - Environment, Packaging Materials and Paper Products, Producer Responsibility Plans; Md. Envir. Title 9, Subtitle 25 Source: Md. Envir. 9-2501 to 9-2512 | E2SSB 5284 - Recycling Reform Act (2025) Source: RCW 70A.208 (E2SSB 5284) |
| PRO / pathwayProducer responsibility organization | Circular Action Alliance (the only approved PRO; producers may form their own under the RMA) Source: ORS 459A.869; NAW v. Feldon ECF 205 · ORS 459A.860 to 459A.975 · CAA | Circular Action Alliance (packaging and paper); Interchange 360 (LPMA) runs a separate CDPHE-approved individual program for automotive lubricant packaging Source: C.R.S. 25-17-708(1) · C.R.S. 25-17-701 to 25-17-715 (HB 22-1355) · CAA | Circular Action Alliance Source: PRC 42051 · PRC 42040 et seq. (SB 54) · CAA | No SO. RFP-202605094 closed Aug 18, 2026 with zero proposals; CAA declined to bid; DEP said Sep 11, 2026 it will revise and reissue the RFP, with no date given Source: 38 MRSA 2146(3) · 38 MRSA 2146 · CAA | Circular Action Alliance Source: Minn. Stat. 115A.1443 · Minn. Stat. 115A.144 to 115A.1463 · CAA | Circular Action Alliance (single approved PRO; additional PROs possible only from Jul 1, 2033) Source: Md. Envir. 9-2502(a), 9-2505 · Md. Envir. 9-2501 to 9-2512 · CAA | Circular Action Alliance Source: RCW 70A.208 (E2SSB 5284 Sec. 104(1)(a)) · RCW 70A.208 (E2SSB 5284) · CAA |
| Fee startWhen producer fees begin | July 1, 2025 (active) Source: CAA Oregon fee schedule · Oregon DEQ · CAA | January 2026 (active) Source: CAA Colorado dues; CAA 2026 Producer Report Planning · Colorado CDPHE · CAA | 2026 early fees invoiced from August 2026; program fees 2027 (post program plan approval) Source: CAA California plan Ch. 9 · CalRecycle · CAA | Not established; DEP is reassessing its start-up registration and invoicing dates after the RFP drew no bids | No producer fee start date set; the first reimbursement floor is Feb 1, 2029 (50% of net costs, 115A.1455 subd. 4), and the PRO may charge member fees earlier (115A.1443 subd. 3(c)) Source: Minn. Stat. 115A.1443 subd. 3(c), 115A.1455 subd. 4 · Minnesota MPCA · CAA | No producer fee start date set; the first reimbursement floor is Jul 1, 2028 (Md. Envir. 9-2505(e)(1)(ii)), and PRO registration fees pass to members now (COMAR 26.04.14.07C(2)) Source: COMAR 26.04.14.10 · Maryland MDE · CAA | 2027 early fees published October 1, 2026 (CAA, eight per-pound rates; invoice timing not published; RCW 70A.208.040(3)(b)); cost-share ramp Feb 15, 2030 to 2032 Source: RCW 70A.208 (E2SSB 5284 Sec. 104(3)(b), 117(2)(a)) · Washington Ecology · CAA |
| Fee schedulePublished, draft, or not yet set | Published. The 2027 Oregon Producer Fees Schedule, published October 1, 2026, sets a rate for each material category and replaces the 2026 schedule of October 29, 2025. Source: 2027 Oregon Producer Fees Schedule (published Oct 1, 2026) · CAA | Published. The 2027 Colorado Producer Dues Schedule, published October 1, 2026, sets a rate for each material category with the passive eco-modulation factors already inside those rates, and replaces the 2026 schedule of October 13, 2025. Source: 2027 Colorado Producer Dues Schedule (published Oct 1, 2026) · CAA | Two schedules run at once. The 2026 California Early Fee Schedule is published and is what CAA invoices for program year 2026, at six flat per-pound rates. The ongoing per-category program fee starts in 2027; CAA published preliminary rates on October 1, 2026, non-binding until CalRecycle approves the program plan. Source: 2026 California Early Fee Schedule; 2027 California Producer Fees Schedule (preliminary, Oct 1, 2026) · CAA | None published. The producer payment schedule is a DEP rule and no stewardship organization is under contract to operate against it. Source: 38 MRSA 2146(13) · 38 MRSA 2146 | None published. Fee structure is set in the stewardship plan, whose statutory due date is October 1, 2028 (115A.1451 subd. 1). Source: Minn. Stat. 115A.1454 · Minn. Stat. 115A.144 to 115A.1463 | None published. Source: Md. Envir. 9-2505(e)(3) · Md. Envir. 9-2501 to 9-2512 | Early fees published. CAA published the 2027 Washington Early Fees Schedule on October 1, 2026, with eight per-pound rates by material category and no invoice date. Program fees follow plan approval. Source: RCW 70A.208.040(3)(b); 2027 Washington Early Fees Schedule (published Oct 1, 2026) · RCW 70A.208 (E2SSB 5284) |
| Required reportingData years reported and the due dates | Mar 31, 2025: CY2024 Annual Supply Report due (a date CAA set; no statute sets it); this is the report the 2026 fee invoices are calculated from May 31, 2026: 2025 Annual Supply Report due (a date CAA set; no statute sets it) Source: Oregon DEQ · CAA | Jul 31, 2025: PPA signing + 2024 supply data due May 31, 2026: 2025 Annual Supply Report due (CAA-set date, not statutory) Source: Colorado CDPHE · CAA | May 31, 2026: Three producer filings due to CAA: 2026 Baseline Producer Report (CY2023 data), Annual Supply Report (CY2025), Annual Source Reduction Report (CY2025). CAA's report-planning dates; the baseline supply data is due with the PRO application within 30 days after May 1 under 14 CCR 18980.5(b), (d), and CAA's May 2026 California guidance treats that deadline as June 1, 2026 because May 31 was a Sunday Aug 17, 2026: CAA scheduled 2026 Early Fee invoices for the week of Aug 17, calculated from 2025 supply data, payment due within 45 days of the invoice date (CAA producer bulletin, Aug 2026), as one installment (CAA 2026 Producer Report Planning table). The CAA newsletter of September 29, 2026 confirms the invoices were issued; CAA has not published the issue date Source: CalRecycle · CAA | Not running today. Chapter 428 sets May 31 as the annual reporting date once a stewardship organization is under contract. | May 31, 2026: Interim Producer Report (simplified reporting categories) due (CAA-set date, not statutory) Source: Minnesota MPCA · CAA | May 31, 2026: Producer registration and Interim Producer Report (simplified reporting categories) due (CAA-set date); COMAR 26.04.14 fixes no May 31 date Source: Maryland MDE · CAA | May 31, 2026: Interim Producer Report (simplified reporting categories) due (CAA-set date, not statutory) Source: Washington Ecology · CAA |
| De minimisSmall-producer test | under 1 metric ton of covered products sold into Oregon or under $5 million gross revenue, either one enough, with associated producers aggregated (ORS 459A.863(32)(c) and (d); OAR 340-090-0860(6)) Source: ORS 459A.863(32) · ORS 459A.860 to 459A.975 | less than one ton of covered materials into Colorado, or under the Producer Exemption Dollar Limit of $5,779,297 as of July 1, 2026 (either qualifies; C.R.S. 25-17-713(1)(a) and (b); 6 CCR 1007-2 Part 1 s1.8.2) Source: C.R.S. 25-17-713 · C.R.S. 25-17-701 to 25-17-715 (HB 22-1355) | <$1M CA gross sales - must apply Source: PRC 42060(a)(5) · PRC 42040 et seq. (SB 54) | <1 ton into ME OR <$2M total gross revenue OR more than 50% of revenue from goods acquired through insurance salvages, closeouts, bankruptcies, and liquidations (2146(2)(C)); any one qualifies; the revenue line is $5M for the period from one year to three years after the SO contract takes effect (38 MRSA 2146(2)). Statute and Chapter 428 both say "ton" without specifying metric or short Source: 38 MRSA 2146(2) · 38 MRSA 2146 | Under 1 ton introduced into Minnesota OR under $2M global gross revenue (Minn. Stat. 115A.1441 subd. 13) Source: Minn. Stat. 115A.1441 subd. 13 · Minn. Stat. 115A.144 to 115A.1463 | <1 ton OR <$2M global revenue Source: Md. Envir. 9-2501 · Md. Envir. 9-2501 to 9-2512 | Under 1 ton of covered materials, under $5M global gross revenue excluding on-premises alcohol sales, or an agricultural employer under $5M in Washington consumer sales of own-brand agricultural commodities; any one qualifies (RCW 70A.208.020(16)) Source: RCW 70A.208.020(16) · RCW 70A.208 (E2SSB 5284) |
| Covered scopeWhat packaging is in scope | Packaging of all materials (plastics, glass, metals, paper/paperboard, composites, multi-material), including B2B, reusable, and storage packaging; scope is not limited to consumer or single-use packaging (DEQ RMA Exemptions FAQ A6; OAR 340-090-0840(1)). Covered products also include printing and writing paper, where the publisher is the producer for catalogs, magazines, newspapers, and directories, and food serviceware (ORS 459A.863(6)(a); 459A.866(2)(a)). Excludes: packaging regulated under Oregon bottle deposit law (ORS 459A), including wine in cans from July 1, 2025 under SB 1520 (2022), drug packaging (ORS 459A.863(6)(b)(M)), packaging of sterile 510(k)-cleared Class II and of Class III medical devices (OAR 340-090-0840(2)(b)), and packaging for long-term (five or more years) storage of a durable good (OAR 340-090-0840(2)(a)). Tertiary packaging is not simply excluded (non-consumer pallet wrap is priced at 34.0 c/lb in 2026 and 12 c/lb in 2027, and tertiary corrugated is zero-rated but still reportable), and there is no general hazard-based exclusion: DEQ states packaging containing hazardous substances is by and large in scope, with narrow exclusions for restricted-use pesticides sold to licensed applicators and certain other agricultural chemicals (OAR 340-090-0840(2)(d)) and for products that federal rules require to be labeled not for recycling (ORS 459A.863(6)(b)(Q)). Oregon prices plastic hazardous-product containers at 63 c/lb in 2026 and 48 c/lb in 2027. Source: ORS 459A.863(6); OAR 340-090-0840 · ORS 459A.860 to 459A.975 · OAR 340-090 (Division 90) | Consumer-facing packaging including plastics, glass, metals, paper/paperboard, and composite materials. Also includes paper products such as catalogs, directories, and magazines; print publications of news and current events are excluded (C.R.S. 25-17-703(13)(b)(XIII)). Excludes: packaging used solely in transportation to nonconsumers, drug and medical device packaging, packaging containing a FIFRA-regulated product, and Poison Prevention Packaging Act packaging. Colorado has no OSHA or DOT exclusion. Source: C.R.S. 25-17-703(13), (25) · C.R.S. 25-17-701 to 25-17-715 (HB 22-1355) · 6 CCR 1007-2 Part 1, Section 18 | Single-use packaging of any material that is routinely recycled, disposed of, or discarded, plus plastic single-use food service ware (PRC 42041(e)(1)); primary, secondary, and tertiary packaging are all in scope. Excludes: packaging for medical products, devices, and prescription drugs, FIFRA products, OSHA-classified hazardous or flammable products, beverage containers under the CA Beverage Container Recycling Program, architectural paint containers, and long-term storage packaging as determined by CalRecycle (42041(e)(2)). Source: PRC 42041(e) · PRC 42040 et seq. (SB 54) · 14 CCR 18980 et seq. | Packaging material that contains, protects, delivers, or presents a product at the time it leaves a point of sale with, or is received by, the consumer (38 MRSA 2146(1)(I)); Maine covers no paper products. Statutory exclusions: long-term storage of durable products, beverage containers under the bottle bill, architectural paint containers under a performing paint stewardship program, and material DEP excludes by rule. No medical, pharmaceutical, or hazardous exclusion by statute or rule (2146(13)(D) requires only a DEP review); hazardous packaging is a distinct chargeable material type under DEP Chapter 428. Source: 38 MRSA 2146(1)(I) · 38 MRSA 2146 · Maine DEP Chapter 428 | Packaging of all materials and paper products introduced into Minnesota (Minn. Stat. 115A.1441 subd. 10); packaging includes pallets, blocking, and bracing and is not limited to consumer packaging. De minimis: under 1 ton of covered material introduced into Minnesota OR under $2M global gross revenue, and either alone qualifies (Minn. Stat. 115A.1441 subd. 13). Excludes: pharmaceutical/medical packaging, FIFRA packaging, and refillable LPG containers. Minnesota's hazardous (OSHA) exclusion applies as determined by the commissioner (subd. 16(11)). Source: Minn. Stat. 115A.1441 subd. 10, 16 · Minn. Stat. 115A.144 to 115A.1463 | Covered packaging materials (all consumer-facing packaging types) and paper products. MDE must develop a statewide list of recyclable or compostable covered materials by Jul 1, 2027 (Md. Envir. 9-2508(a)(1)); no publication date is set. Exempt materials include primary packaging for FDA-regulated drugs, medical devices, and medical equipment, and primary packaging for OSHA-regulated hazardous or flammable products where the Department determines the packaging cannot be waste reduced or made reusable, recyclable, or compostable (COMAR 26.04.14.02B(16)). Secondary and tertiary packaging for these products is not exempt, because each of these exemptions reaches primary packaging only. Source: COMAR 26.04.14.02B, .04B; Md. Envir. 9-2508 · Md. Envir. 9-2501 to 9-2512 · COMAR 26.04.14 | Consumer-facing packaging of all material types and paper products. Scope largely mirrors other CAA-administered states. De minimis: any one of three tests qualifies (RCW 70A.208.020(16)): under 1 ton of covered materials, OR under $5M global gross revenue excluding on-premises alcohol sales, OR an agricultural employer with under $5M in Washington revenue from own-brand agricultural commodities. All three tests apply now. Sec. 109 set October 1, 2026 for Ecology's initial statewide collection lists; preliminary lists were out for comment August 5 to 19, 2026, and Ecology's program page says the lists will be published by 2027. Ecology publishes final lists within 30 days of approving a plan (E2SSB 5284 Sec. 109); the statutory due date for the PRO program plan is Oct 1, 2028 (Sec. 113(1)). Source: RCW 70A.208.020(19), (25); .090 · RCW 70A.208 (E2SSB 5284) |
| Key exemptionsMaterial-side carve-outs; entity relief noted | Out: medical and drug, refillable LPG, agricultural, long-term storage, paint containers Conditional: B2B and transport, pesticides (FIFRA), beverage or deposit containers No provision (in scope): hazardous (OSHA), DOT dangerous goods All 19 rows → Source: ORS 459A.863(6)(b); OAR 340-090-0840(2) · ORS 459A.860 to 459A.975 · OAR 340-090 (Division 90) | Out: pesticides (FIFRA), medical and drug, long-term storage, paint containers Entity relief: agricultural [unsettled] Conditional: B2B and transport, beverage or deposit containers No provision (in scope): hazardous (OSHA), DOT dangerous goods, refillable LPG All 19 rows → Source: C.R.S. 25-17-703(13)(b), 25-17-713 · C.R.S. 25-17-701 to 25-17-715 (HB 22-1355) · 6 CCR 1007-2 Part 1, Section 18 | Out: hazardous (OSHA), DOT dangerous goods, pesticides (FIFRA), beverage or deposit containers, medical and drug, paint containers Entity relief: agricultural Conditional: long-term storage (agency determination) No provision (in scope): B2B and transport, refillable LPG All 19 rows → Source: PRC 42041(e)(2), (w)(4) · PRC 42040 et seq. (SB 54) · 14 CCR 18980 et seq. | Out: beverage or deposit containers, long-term storage Conditional: B2B and transport, paint containers (agency determination) No provision (in scope): hazardous (OSHA), DOT dangerous goods, pesticides (FIFRA), medical and drug, refillable LPG, agricultural All 19 rows → Source: 38 MRSA 2146(1)(C-1), (1)(I) · 38 MRSA 2146 · Maine DEP Chapter 428 | Out: pesticides (FIFRA), medical and drug, refillable LPG, paint containers Conditional: B2B and transport, hazardous (OSHA) (agency determination) [unsettled] No provision (in scope): DOT dangerous goods, beverage or deposit containers, agricultural, long-term storage All 19 rows → Source: Minn. Stat. 115A.1441 subd. 16 · Minn. Stat. 115A.144 to 115A.1463 | Out: B2B and transport, pesticides (FIFRA), medical and drug, refillable LPG, paint containers Conditional: hazardous (OSHA) (agency determination), beverage or deposit containers, long-term storage (agency determination) No provision (in scope): DOT dangerous goods, agricultural All 19 rows → Source: COMAR 26.04.14.02B(16), .05B · Md. Envir. 9-2501 to 9-2512 · COMAR 26.04.14 | Out: B2B and transport, pesticides (FIFRA), medical and drug, refillable LPG, long-term storage, paint containers Entity relief: agricultural [unsettled] Conditional: hazardous (OSHA) (agency determination) [unsettled] No provision (in scope): DOT dangerous goods, beverage or deposit containers All 19 rows → Source: RCW 70A.208.020(16), (19) · RCW 70A.208 (E2SSB 5284) |
| Eco-modulationBonuses and maluses on fees | Bonus-only this cycle; LCA dollar caps apply per SKU or batch and per producer. confirmed Detail → Source: ORS 459A.884(4); OAR 340-090-0900 to 0940; CAA Oregon plan · OAR 340-090 (Division 90) · CAA | Passive factors are already inside the published 2026 and 2027 dues rates. The four active bonuses are 1% each in rule; the rule requires the PRO to apply them to invoices no later than January 31, 2028, and CAA's 2026 dues schedule says four active incentives are available for the 2026 program year, so timing turns on CAA's guidance. confirmed Detail → Source: 6 CCR 1007-2 Sec. 18.9 · 6 CCR 1007-2 Part 1, Section 18 · CAA | Not set in the preliminary 2027 schedule (October 1, 2026), which applies the two passive factors at 5 percent each; the plan says incentives must not exceed a producer's total payable base fees (section 10.3), and the PCR and source-reduction bonus values are not yet published. signaled Detail → Source: PRC 42053(e); CAA California plan Ch. 6 and 10 · 14 CCR 18980 et seq. · CAA | Not established - no SO exists to file a stewardship plan. pending Detail → Source: 38 MRSA 2146(13) · Maine DEP Chapter 428 · CAA | Not established - stewardship plan due Oct 1, 2028. pending Detail → Source: Minn. Stat. 115A.1454 · Minn. Stat. 115A.144 to 115A.1463 · CAA | Not established - rules in development. pending Detail → Source: Md. Envir. 9-2505(e)(3) · COMAR 26.04.14 · CAA | Not established - program plan pending. pending Detail → Source: RCW 70A.208 (E2SSB 5284 Sec. 116(2)(c)) · RCW 70A.208 (E2SSB 5284) · CAA |
| Max penaltyNon-compliance exposure | Up to $25,000 per day for each day of violation. DEQ assesses under ORS 459A.962(4) and the ceiling is set by ORS 459.995(1)(a), which names ORS 459A.860 to 459A.975; DEQ starts from the OAR 340-012-0140 base-penalty matrix Source: ORS 459A.962(4); OAR 340-012-0140 · ORS 459A.860 to 459A.975 | Administrative penalty of up to $5,000 for the first day plus up to $1,500 per day, rising to up to $20,000 plus $6,000 per day for a third violation within 12 months (C.R.S. 25-17-710(1), each tier "not to exceed"); sales prohibition for non-participants (25-17-708(1)) Source: C.R.S. 25-17-710(1), 25-17-708(1) · C.R.S. 25-17-701 to 25-17-715 (HB 22-1355) | Up to $50,000/day/violation; $25,000 for small producers Source: PRC 42081(a)(1) · PRC 42040 et seq. (SB 54) | DEP enforces (Chapter 428 final rules Dec 2024, amended March 3, 2026, filing 2026-056) Source: 38 MRSA 2146(13) · 38 MRSA 2146 | Up to $25,000/day, rising to $50,000 then $100,000 for repeat violations (115A.1462(c)); the $50,000 and $100,000 tiers apply to repeat violations within five years after stewardship plan approval Source: Minn. Stat. 115A.1462 · Minn. Stat. 115A.144 to 115A.1463 | $5,000–$20,000 per violation Source: COMAR 26.04.14.11B · COMAR 26.04.14 | Up to $1,000 per violation per day, $10,000 per violation per day for the second and each later violation, after 60-day written notice (E2SSB 5284 Sec. 123(1)) Source: RCW 70A.208 (E2SSB 5284 Sec. 123) · RCW 70A.208 (E2SSB 5284) |
| Next actionNext tracked milestone after October 8, 2026 | Oct 16, 2026: Joint status report due in Lollicup, not later than this date (ECF 12, order of Sep 10, 2026 granting the ECF 11 joint motion) Source: Oregon DEQ · CAA | Oct 14, 2026: Interchange 360 producer webinar on its Colorado eco-modulation guidance, 1:00 p.m. ET; its 5 percent PCR bonus applies from January 1, 2027 (Interchange 360 webinar page; Interchange 360 Colorado Producer Eco-Modulation Guidance, October 2026) Source: Colorado CDPHE · CAA | Oct 13, 2026: CAA program plan due to CalRecycle, for approval on or before Jan 1, 2027 (CAA newsletter, Sep 29, 2026) Source: CalRecycle · CAA | No dated milestone on the record. | Nov 13, 2026: Comment closes on the MPCA draft 2026 Needs Assessment Source: Minnesota MPCA · CAA | Oct 8, 2026: Packaging and Paper Products Advisory Council meeting, 9 to 11 a.m. ET, open to the public with time for comment (CAA newsletter, Sep 29, 2026; MDE does not post the date) Source: Maryland MDE · CAA | Oct 8, 2026: Recycling Reform Act Advisory Council meeting, 10 a.m. to 2 p.m. PT, hybrid, in person at the WM Spokane SMaRT Center (RRA Advisory Council site) Source: Washington Ecology · CAA |
Labels used in the table. confirmed is read from an adopted rule, statute, or published schedule; signaled is official but not final; pending means the rule is not set and the cell says so. In the exemptions row, "no provision" means the instrument names no carve-out, so the material is in scope; "conditional" means a test applies; "entity relief" means the producer, not the material, is exempt. Source links open the official publisher. Not legal advice; verify anything consequential with the agency, the CAA, or counsel.
Facts on this page were last verified against primary sources on October 8, 2026. The EPR Atlas is re-checked weekly, and this stamp moves only when a verification pass runs.
The table stays free to read on this page. The CSV holds the states and categories you have selected, with the cited provision for each cell. Add your details once and the download starts, and the same access covers the Unit EPR Fee Calculator and the DFR Rater.
SB 582, Plastic Pollution & Recycling Modernization Act (2021). Fees are active (July 1, 2025). The de minimis exemption is under 1 metric ton of covered products sold into Oregon or under $5 million gross revenue, either one enough, with associated producers aggregated (ORS 459A.863(32)(c) and (d); OAR 340-090-0860(6)). Maximum penalty: Up to $25,000 per day for each day of violation. DEQ assesses under ORS 459A.962(4) and the ceiling is set by ORS 459.995(1)(a), which names ORS 459A.860 to 459A.975; DEQ starts from the OAR 340-012-0140 base-penalty matrix. Administered by Oregon DEQ through Circular Action Alliance (the only approved PRO; producers may form their own under the RMA). Full Oregon EPR compliance guide →
HB 22-1355, Producer Responsibility Program for Statewide Recycling (2022). Fees are active (January 2026). The de minimis exemption is less than one ton of covered materials into Colorado, or under the Producer Exemption Dollar Limit of $5,779,297 as of July 1, 2026 (either qualifies; C.R.S. 25-17-713(1)(a) and (b); 6 CCR 1007-2 Part 1 s1.8.2). Maximum penalty: Administrative penalty of up to $5,000 for the first day plus up to $1,500 per day, rising to up to $20,000 plus $6,000 per day for a third violation within 12 months (C.R.S. 25-17-710(1), each tier "not to exceed"); sales prohibition for non-participants (25-17-708(1)). Administered by Colorado CDPHE through Circular Action Alliance (packaging and paper); Interchange 360 (LPMA) runs a separate CDPHE-approved individual program for automotive lubricant packaging. Full Colorado EPR compliance guide →
SB 54, Plastic Pollution Prevention & Packaging Producer Responsibility Act (2022). Program fees begin in 2027 (post program plan approval) under CAA's preliminary fee schedule, after a 2026 Early Fee. The de minimis exemption is <$1M CA gross sales, must apply. Maximum penalty: Up to $50,000/day/violation; $25,000 for small producers. Administered by CalRecycle through Circular Action Alliance. Full California EPR compliance guide →
LD 1541 (2021) / LD 1423 (signed Jun 2025). No producer fee start date is set; DEP is reassessing its start-up registration and invoicing dates after the RFP drew no bids. The de minimis exemption is <1 ton into ME OR <$2M total gross revenue OR more than 50% of revenue from goods acquired through insurance salvages, closeouts, bankruptcies, and liquidations (2146(2)(C)); any one qualifies; the revenue line is $5M for the period from one year to three years after the SO contract takes effect (38 MRSA 2146(2)). Statute and Chapter 428 both say "ton" without specifying metric or short. DEP enforces the program (Chapter 428 final rules Dec 2024, amended March 3, 2026, filing 2026-056). Administered by Maine DEP, with no stewardship organization in place. RFP-202605094 closed Aug 18, 2026 with zero proposals; CAA declined to bid; DEP said Sep 11, 2026 it will revise and reissue the RFP, with no date given. Full Maine EPR compliance guide →
HF 3911, Packaging Waste and Cost Reduction Act (2024). No producer fee start date is set; the first reimbursement floor is Feb 1, 2029 (50% of net costs, 115A.1455 subd. 4), and the PRO may charge member fees earlier (115A.1443 subd. 3(c)). The de minimis exemption is under 1 ton introduced into Minnesota OR under $2M global gross revenue (Minn. Stat. 115A.1441 subd. 13). Maximum penalty: Up to $25,000/day, rising to $50,000 then $100,000 for repeat violations (115A.1462(c)); the $50,000 and $100,000 tiers apply to repeat violations within five years after stewardship plan approval. Administered by Minnesota MPCA through Circular Action Alliance. Full Minnesota EPR compliance guide →
SB 901 (Ch. 431 of 2025), Environment, Packaging Materials and Paper Products, Producer Responsibility Plans; Md. Envir. Title 9, Subtitle 25. No producer fee start date is set; the first reimbursement floor is Jul 1, 2028 (Md. Envir. 9-2505(e)(1)(ii)), and PRO registration fees pass to members now (COMAR 26.04.14.07C(2)). The de minimis exemption is <1 ton OR <$2M global revenue. Maximum penalty: $5,000–$20,000 per violation. Administered by Maryland MDE through Circular Action Alliance (single approved PRO; additional PROs possible only from Jul 1, 2033). Full Maryland EPR compliance guide →
E2SSB 5284, Recycling Reform Act (2025). Early fees for 2027 were published October 1, 2026 (CAA, eight per-pound rates; invoice timing not published; RCW 70A.208.040(3)(b)); cost-share ramp Feb 15, 2030 to 2032. The de minimis exemption is under 1 ton of covered materials, under $5M global gross revenue excluding on-premises alcohol sales, or an agricultural employer under $5M in Washington consumer sales of own-brand agricultural commodities; any one qualifies (RCW 70A.208.020(16)). Maximum penalty: Up to $1,000 per violation per day, $10,000 per violation per day for the second and each later violation, after 60-day written notice (E2SSB 5284 Sec. 123(1)). Administered by Washington Ecology through Circular Action Alliance. Full Washington EPR compliance guide →
The comparison above puts every field beside every state. For a single question, these pages cover it in more depth.
Beyond the seven enacted states, packaging EPR bills have been introduced in states including New York, New Jersey, Massachusetts, Illinois, and Michigan. None have been enacted yet, and several have stalled across sessions. The EPR Atlas hub tracks pending legislation and posts a weekly What's New update.
Every state guide has the fee schedule where one has been published, registration deadlines, eco-modulation detail, and exemptions. Start with a state, or estimate your costs in the fee calculator.