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 September 9, 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)
Not established; cost-share ramp 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
SB 54, Plastic Pollution Prevention & Packaging Producer Responsibility Act (2022). Administered by CalRecycle through Circular Action Alliance.
Mar 7, 2025: Gov. Newsom directs CalRecycle to restart SB 54 rulemaking
Mar 9, 2026: AB 2253 (recycled content claims) referred to committee
Late May 2026: AB 2253 passed Assembly 42-19; ordered to Senate
Jul 1, 2026: AB 2253 cleared Senate Environmental Quality 4-2; re-referred to Senate Appropriations
Jul 2, 2026: AB 2253 amended: the credit-based mass balance prohibition is struck from the bill
Aug 3, 2026: AB 2253 placed on the Senate Appropriations suspense file 7-0
Aug 13, 2026: AB 2253 out of Senate Appropriations 5-2, do pass as amended; amendment expressly permits proportional attribution (ISO 22095-2:2026); applies to all products from Jan 1, 2030
Mar 17, 2026: SB 343 constitutional challenge filed (21 organizations; Case 3:26-cv-01675)
Jun 2, 2026: Oceana, NRDC, and Californians Against Waste sued CalRecycle over SB 54 regs (S.F. Superior Court)
Jun 22, 2026: 17-state AG coalition + NAW filed federal challenge to SB 54 (E.D. Cal.)
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-set dates; 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 3, 2026: Individual Source Reduction Plans due to CAA
Aug 14, 2026: Public comment period on the draft program plan closes
Aug 2026: CAA invoices early pre-program fees (one installment, based on CY2025 data)
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
LD 1541 (2021) / LD 1423 (signed Jun 2025). Administered by Maine DEP through No SO. RFP-202605094 closed Aug 18, 2026 with zero proposals; CAA declined to bid.
Jun 15, 2026: DEP issued SO selection RFP-202605094
Aug 18, 2026: RFP closed with ZERO proposals; CAA declined to bid Aug 19
Aug 20, 2026: DEP announced no bids and is assessing all options
May 31 (annual): Producer reporting, on DEP's fixed annual calendar
Jul 1 (annual): Producer invoicing
Sep 1 (annual): Producer payment
Oct 1 (annual): Municipal reimbursement
TBD: Startup fees would be due within 180 days of an SO contract, and only from producers other than low-volume producers (Ch. 428); no SO exists after the Aug 18, 2026 RFP drew no bids
TBD: Full program operational if an SO is designated on the revised schedule
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
E2SSB 5284, Recycling Reform Act (2025). Administered by Washington Ecology through Circular Action Alliance.
May 31, 2026: Simplified Supply Report due (CAA-set date, not statutory)
Jul 1, 2026: Producers must be PRO members (statutory, E2SSB 5284 Sec. 104(1)(a))
Aug 5, 2026: Ecology publishes preliminary statewide collection lists; public comment closes Aug 19, 2026
Sep 1, 2026: CAA (as PRO) one-time payment to Ecology due, covering Ecology costs from Jul 27, 2025 through Jun 30, 2027; amount set by Ecology. Also binds an individual producer registered as its own PRO. Statutory: RCW 70A.208.040(3)(a)(ii)
Sep 29, 2026: Draft preliminary needs assessment to Ecology and the advisory council; public comment Sep 2026
Dec 31, 2026: Final preliminary needs assessment
Mar 31, 2027: Ecology determines the PRO annual registration fee, and every Mar 31 thereafter. Statutory: RCW 70A.208.030(4)(a)
May 1, 2027: PRO begins paying Ecology the annual registration fee. Statutory: RCW 70A.208.040(3)(a)(iii)
Sep 2027: Draft full needs assessment out for public comment
Dec 31, 2027: Final full needs assessment
Oct 1, 2028: PRO submits program plan
Mar 1, 2029: Ecology begins enforcement
Feb 15, 2030: 50% cost-share milestone; full fees begin
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.