Active Program

Maine Packaging EPR: Producer Compliance Guide

Maine's LD 1541 (2021), amended by LD 1423 (signed June 2025), was the first U.S. state to enact packaging EPR. The program is still in its pre-operational phase as of mid-2026: Maine DEP issued its Stewardship Organization (SO) selection RFP on June 15, 2026, but no SO has been selected yet and no fee clock has started. Note that Maine uses the term Stewardship Organization (SO), not PRO -- the Circular Action Alliance has stated its intent to respond to the RFP. Startup fees are expected in late 2026, contingent on SO selection and contract signing. Fees are due within 180 days of the SO contract. Maine's de minimis threshold is less than 1 metric ton OR approximately less than $2 million in revenue -- either condition alone grants full exemption.

Governing Law
LD 1541 (2021) / LD 1423 (signed Jun 2025)
Fee Start
Late 2026, contingent on SO selection
Max Penalty
DEP enforces (final rules Dec 2024)
Administering Agency
Maine DEP
PRO / Administrator
SO pending - RFP issued Jun 2026; CAA intends to respond
De Minimis
<1 ton OR <~$2M revenue
Fees are not yet active. Amounts shown are projections based on Oregon's published 2025-26 rates at the Maine program multiplier (0.8x). Actual rates will be set when the program plan is approved.

Fee Schedule by Material

Base rates before eco-modulation. Final fee = Tonnage x Rate x Eco-Modulation Multiplier. All amounts are projections; actual rates set upon program plan approval.

Material / Packaging TypeRate / Metric TonTier
Aluminum, cans $96 (est.) Tier 1
Clear PET (#1) $400 (est.) Tier 2-3
HDPE Natural (#2) $144 (est.) Tier 1
Steel $160 (est.) Tier 1
Uncoated Paper/Board $128 (est.) Tier 1
Corrugated $128 (est.) Tier 1
HDPE Pigmented (#2) $512 (est.) Tier 2-3
PP (#5) $608 (est.) Tier 4
Glass $160 (est.) Tier 1
LDPE Film / Mono-PE $688 (est.) Tier 4
PS Rigid (#6) $1,552 (est.) Tier 4
Expanded Polystyrene $2,208 (est.) Tier 4

Eco-Modulation Factors

○ SpeculativeProjected/estimated. Eco-modulation rules are not yet finalized in this state.

Source: LD 1541 (2021) / LD 1423 (2025) statute; Maine DEP Chapter 428. SO not yet selected; eco-modulated fee schedule not established (full eco-mod fees come in later years).

Eco-modulation adjusts fees based on packaging design and recyclability attributes.

Fee Reductions (Bonuses)

Expected (not finalized): credit for widely recyclable formats Expected: PCR content incentive Expected: reuse treatment

Fee Increases (Maluses)

Expected (not finalized): higher fee for hard-to-recycle materials

Multiplier floor: Not established - eco-mod schedule pending SO selection

ℹ️
SPECULATIVE: Maine's eco-mod specifics are not yet established. Maine DEP issued the SO selection RFP on June 15, 2026 (no SO selected yet); startup fees expected late 2026; full program operational 2027-28. Specific factors and rates will be set later.

Key Dates and Timeline

Jun 15, 2026
DEP issued the SO selection RFP; CAA intends to respond
Late 2026
Startup fees expected once an SO contract is signed; payment is due within 180 days of that contract
2027–28
Full program operational if SO is designated on the revised schedule

Covered Products Scope

Consumer-facing primary and secondary packaging, paper products (newspapers, magazines, catalogs, telephone directories). Excludes: B2B-only tertiary packaging, pharmaceutical/medical packaging, DOT-regulated hazmat containers, and packaging with >50% non-packaging function.

Exemptions and Exclusions

The following categories may be fully or partially exempt from producer obligations in Maine. Verify applicability with the CAA producer portal or Maine DEP before excluding any materials from supply reports.

De Minimis (Small Producer)
<1 ton placed on market OR <~$2M global revenue (either qualifies)
B2B / Tertiary Packaging
Tertiary/transport packaging used exclusively B2B (never reaching consumers) excluded
Medical Device and Pharmaceutical
Packaging for pharmaceutical products and FDA-regulated medical devices excluded under Maine DEP rules
Hazardous Materials Packaging
Packaging required for hazardous materials regulated under separate federal/state programs excluded
Maine program is pre-operational (startup fees begin late 2026). Stewardship Organization not yet designated - final exemption details will be confirmed in the SO-approved stewardship plan.

Frequently Asked Questions

Does Maine use the term PRO for its program administrator?
No. Maine uses the term Stewardship Organization (SO), not PRO. Do not refer to Maine's administrator as a PRO. The Circular Action Alliance has stated its intent to respond to the SO RFP, which DEP issued on June 15, 2026.
When do Maine EPR fees begin?
Startup fees are expected in late 2026, contingent on SO selection and contract signing. Fees are due within 180 days of the SO contract. DEP issued the SO RFP on June 15, 2026; an SO has not yet been selected, so the timeline remains subject to slippage.
What is Maine's de minimis threshold?
Less than 1 metric ton placed on the Maine market OR approximately less than $2 million in global revenue -- either condition alone grants full exemption.
What level of supply report detail does Maine require?
Maine currently requires a simplified supply report covering estimated 2025 tonnage only -- the least detailed of any enacted U.S. state. Oregon and Colorado require SKU/component-level detail.