Registration dates, supply report deadlines and fee start dates for every U.S. state with an enacted packaging EPR law. Reporting obligations begin years before fees in several states, which is the single most commonly missed part of packaging EPR compliance.
Facts on this page were last verified against primary sources on August 10, 2026. The EPR Atlas is re-checked weekly; this stamp moves only when a verification pass actually runs, not when the site rebuilds.
EPR reporting deadlines at a glance
The three dates that matter to a producer in each state: when you have to register, when your first supply report is due, and when fees start. Registration almost always comes first and is frequently missed, because it can fall years before a single dollar of fee is invoiced.
Jul 1, 2026: Producers must be PRO members (statutory, E2SSB 5284 Sec. 104(1)(a))
May 31, 2026: Simplified Supply Report due (CAA-set date, not statutory)
2029–2030
Deadlines change as rulemaking settles. Confirm current dates in the CAA producer portal or with the state agency before relying on them.
How the sequence works
Every enacted program runs the same four steps in the same order, even though the dates differ. First you determine whether you are the responsible producer for a given item, which is a hierarchy question and not always the obvious answer. Second you register, usually through the Circular Action Alliance producer portal, which serves most states from one registration. Third you file a supply report describing what you sold into the state by material and weight. Fourth, some time later, an invoice arrives based on that data.
The gap between step three and step four is where producers are caught out. Minnesota requires registration from July 2025 but does not invoice until February 2029. Maryland reports now and pays from 2028. Reporting obligations are live in states where no fee has ever been charged.
What happens if you miss one
Most published guidance stops at the deadline table, which leaves the more useful question unanswered. Missing a date does not trigger a penalty on the day it passes. In the CAA-administered states it starts a defined process, and knowing the shape of it is what tells a late producer how much time they actually have.
CAA's Producer Delinquency Policy (Version 2.0, April 2026) lists eight triggers, which between them cover failure to register, failure to report, failure to pay, late reports, unpaid invoices, inaccurate registration or reporting, missing documentation, and non-cooperation with an audit. Escalation runs in four stages: a Notice of Delinquency, reminder notices at CAA's discretion, a Notice of Unresolved Delinquency once the window expires, and then transmission of the delinquency to the state regulator.
The window is the part worth writing down. The policy defines the Delinquency Resolution Period as "three months from CAA's determination of the Delinquency, as reflected by the date the Notice of Delinquency is issued to the Producer", unless the notice names an earlier determination date, in which case the clock runs from that earlier date instead.
Two things follow. A producer that comes in voluntarily is resolving inside that window rather than being escalated to a regulator at the end of it, which is a materially different position. And the escalation is administrative, not a substitute for the statutory penalties: Oregon DEQ can assess up to $25,000 per day, California up to $50,000 per day per violation, counted by brand, product line, covered material category and package size rather than by SKU (PRC 42081(a)(2)), and Maryland $5,000 to $20,000 per violation. The PRO process and the state enforcement power run in parallel.
Oregon is the one state where the consequence is also public. DEQ publishes a quarterly producer status list, and its first, dated April 9, 2026, named roughly 250 companies for failing to register, report or pay. The listing process runs a 90-day CAA contact window and then a 30-day DEQ cure window before a producer appears on it.
Oregon EPR reporting deadlines
SB 582, Plastic Pollution & Recycling Modernization Act (2021). Administered by Oregon DEQ through Circular Action Alliance (mandatory).
Mar 31, 2025: Producer registration with CAA opened; failure to register is a Class 1 violation
Jun 22, 2026: 17-state AG coalition + NAW filed federal challenge to SB 54 (E.D. Cal.)
May 31, 2026: Annual Supply Reports + CY2023 Baseline Source Reduction Report due (CAA-communicated; PRC 42060 delegates reporting timelines to CalRecycle)
Jun 1, 2026: Producer registration deadline (PEPRS/CAA)
Jun 15, 2026: CAA filed its draft 5-year program plan with the Producer Responsibility Advisory Board; 60-day public comment period opens (closes ~Aug 14, 2026)
Aug 1, 2026: Individual Source Reduction Plans due
Aug 14, 2026: Public comment period on the draft program plan closes
Aug 2026: CAA invoices early pre-program fees (August 2026, per CAA's program plan)
Oct 2026: CAA expected to file revised program plan; final 2027 fee schedule published
Jan 1, 2027: Formal program beginning; CalRecycle approves plan
Mar 1, 2027: First California Plastic Pollution Mitigation Fund payment due ($500M/yr)
Jul 1, 2027: First CAA administrative fees remitted to CalRecycle
SB 901, Maryland Packaging and Paper Products Stewardship Act (2025). Administered by Maryland MDE through Circular Action Alliance (multi-PRO system).
May 25, 2026: First implementing regulations effective
May 31, 2026: Producer registration and Simplified Supply Report due (CAA-set date, not statutory); COMAR 26.04.14 fixes no May 31 date
Jul 1, 2026: CAA submits producer/brand/material list to MDE (CAA obligation; producer deadline was May 31)
Jul 1, 2027: MDE publishes statewide covered materials list
It depends on the state, but most enacted programs use a spring annual supply report. In 2026, annual or simplified supply reports were due May 31 in California, Oregon, Minnesota, Maryland and Washington. Registration deadlines run separately and generally come earlier.
Do I have to report in a state that is not charging fees yet?
Usually yes. Registration and supply reporting obligations begin years before fees in several states. Minnesota required producer registration from July 1, 2025 but does not collect fees until February 2029. Maryland and Washington are in the same position. Treat reporting and paying as separate schedules.
Do I register separately in every state?
Generally no. The Circular Action Alliance is the producer responsibility organization in every enacted state except Maine, which uses a Stewardship Organization not yet selected, so a single CAA registration and supply report covers most states. State-specific rules and exemptions still apply on top.
What happens if I miss an EPR deadline?
Penalties vary widely. California allows up to $50,000 per day per violation and does not start the clock until 30 calendar days after notice (PRC 42081(a)(1) and (a)(3)), Oregon up to $25,000 per day, Maryland $5,000 to $20,000 per violation, and Colorado provides for civil penalties plus a sales prohibition. Oregon DEQ also publishes a quarterly public list of noncompliant producers.
Explore each state in depth
Every state guide carries the full fee schedule, registration deadlines, program plan status, eco-modulation detail, statute and rule text, and exemptions.