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.

StateRegistrationFirst or recurring reportFees begin
Oregon Not yet set May 31, 2026: 2025 Annual Supply Report due July 1, 2025
Colorado Jul 31, 2025: PPA signing + 2024 supply data due May 31, 2026: 2025 Annual Supply Report due January 2026
California Jun 1, 2026: Producer registration deadline (PEPRS/CAA) May 31, 2026: Annual Supply Reports + CY2023 Baseline Source Reduction Report due 2027 (post program plan approval)
Maine Not yet set Not yet set Late 2026, contingent on SO selection
Minnesota Jul 1, 2025: Producer registration required May 31, 2026: Simplified Supply Report due Feb 1, 2029 (50% cost-share)
Maryland Not yet set May 31, 2026: Simplified Supply Report due 2028 or later
Washington Jul 1, 2026: Producers must be PRO members May 31, 2026: Simplified Supply Report due 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.

Oregon EPR reporting deadlines

SB 582, Plastic Pollution & Recycling Modernization Act (2021). Administered by Oregon DEQ through Circular Action Alliance (mandatory).

Full Oregon deadline detail →

Colorado EPR reporting deadlines

HB 22-1355, Producer Responsibility Program for Statewide Recycling (2022). Administered by Colorado CDPHE through Circular Action Alliance.

Full Colorado deadline detail →

California EPR reporting deadlines

SB 54, Plastic Pollution Prevention & Packaging Producer Responsibility Act (2022). Administered by CalRecycle through Circular Action Alliance.

Full California deadline detail →

Maine EPR reporting deadlines

LD 1541 (2021) / LD 1423 (signed Jun 2025). Administered by Maine DEP through SO pending - RFP issued Jun 2026; CAA intends to respond.

Full Maine deadline detail →

Minnesota EPR reporting deadlines

HF 3911, Packaging Waste and Cost Reduction Act (2024). Administered by Minnesota MPCA through Circular Action Alliance.

Full Minnesota deadline detail →

Maryland EPR reporting deadlines

SB 901, Maryland Packaging and Paper Products Stewardship Act (2025). Administered by Maryland MDE through Circular Action Alliance (multi-PRO system).

Full Maryland deadline detail →

Washington EPR reporting deadlines

E2SSB 5284, Recycling Reform Act (2025). Administered by Washington Ecology through Circular Action Alliance.

Full Washington deadline detail →

Frequently asked questions

When are EPR reports due?
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, 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.