Active Program

Maryland Packaging EPR: Producer Compliance Guide

Maryland's SB 901 (2025) -- the Maryland Packaging and Paper Products Stewardship Act -- is notable for allowing competing Producer Responsibility Organizations (PROs), though only the Circular Action Alliance is currently registered. First implementing regulations took effect May 25, 2026. Maryland's program uses a cost-share ramp: producers will cover 50% of net recycling costs by July 1, 2028, 75% by July 1, 2029, and 90% by July 1, 2030. The July 1, 2026 date is a CAA obligation to MDE (submission of the producer/brand/material list) -- it is not a producer deadline. Maryland's producer registration and simplified supply report deadline was May 31, 2026.

Governing Law
SB 901 - Maryland Packaging and Paper Products Stewardship Act (2025)
Fee Start
2028 or later
Max Penalty
$5,000–$20,000 per violation
Administering Agency
Maryland MDE
PRO / Administrator
Circular Action Alliance (multi-PRO system)
De Minimis
<1 ton OR <$2M global revenue
Fees are not yet active. Amounts shown are projections based on Oregon's published 2025-26 rates at the Maryland program multiplier (1x). 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 $120 (est.) Tier 1
Clear PET (#1) $500 (est.) Tier 2-3
HDPE Natural (#2) $180 (est.) Tier 1
Steel $200 (est.) Tier 2-3
Uncoated Paper/Board $160 (est.) Tier 1
Corrugated $160 (est.) Tier 1
HDPE Pigmented (#2) $640 (est.) Tier 4
PP (#5) $760 (est.) Tier 4
Glass $200 (est.) Tier 2-3
LDPE Film / Mono-PE $860 (est.) Tier 4
PS Rigid (#6) $1,940 (est.) Tier 4
Expanded Polystyrene $2,760 (est.) Tier 4

Eco-Modulation Factors

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

Source: SB 901 (2025) + first MDE regulations effective May 25, 2026. Eco-mod required by statute; factor schedule not yet established.

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

Fee Reductions (Bonuses)

Expected (not finalized): lower fee for recyclable packaging Expected: PCR content discount

Fee Increases (Maluses)

Expected (not finalized): higher fee for non-recyclable / no-market materials

Multiplier floor: Not established - rules in development

ℹ️
SPECULATIVE for eco-mod. Maryland allows competing PROs (only CAA registered so far). Cost-share ramp 50% (2028) / 75% (2029) / 90% (2030). Statute requires eco-modulated fees (more for materials lacking a recycling market), but specific factors/rates are not yet established.

Key Dates and Timeline

May 25, 2026
First implementing regulations effective
May 31, 2026
Simplified Supply Report due
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
Jul 1, 2028
50% cost-share milestone; fees begin
Jul 1, 2029
75% cost-share milestone
Jul 1, 2030
90% cost-share milestone

Covered Products Scope

Covered packaging materials (all consumer-facing packaging types) and paper products. CMC list to be published by MDE by Jul 1, 2027. Excludes similar categories to other CAA states: B2B tertiary, pharma/medical, hazmat.

Exemptions and Exclusions

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

De Minimis (Small Producer)
<1 ton placed on Maryland market OR <$2M global revenue (either qualifies)
B2B / Tertiary Packaging
Tertiary/transport packaging used exclusively B2B excluded
Medical Device and Pharmaceutical
Packaging for prescription drugs and FDA-regulated medical devices excluded
Hazardous Materials Packaging
Packaging for hazardous materials regulated under separate federal/state programs excluded
Maryland program is in ramp-up phase. Full exemption rules are still being finalized by MDE. Verify current scope with CAA producer portal or MDE guidance documents.

Frequently Asked Questions

What is the July 1, 2026 deadline in Maryland?
July 1, 2026 is a CAA obligation -- not a producer deadline. CAA must submit its producer, brand, and material list to Maryland MDE by that date. Maryland's producer registration and simplified supply report deadline was May 31, 2026.
When do Maryland EPR fees begin?
Maryland fees are expected to begin in 2028 or later. The cost-share ramp begins July 1, 2028 (50%), reaching 75% by July 1, 2029 and 90% by July 1, 2030.
Can multiple PROs operate in Maryland?
Yes. Maryland allows competing PROs -- the only enacted U.S. state to do so. However, only the Circular Action Alliance is currently registered as of mid-2026.
What is Maryland's de minimis threshold?
Less than 1 metric ton placed on the Maryland market OR less than $2 million in global revenue -- either condition alone grants full exemption.