EPR Scope Screener: Which States Cover You?

Packaging EPR obligation turns on who you are, what you sell and how big you are, and every enacted state draws those lines a little differently. Answer the questions below to see which of the seven states with enacted packaging EPR laws are likely to treat your company as an obligated producer, and which are likely to exempt you.

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Facts on this page were last verified against primary sources on August 3, 2026. The EPR Atlas is re-checked weekly; this stamp moves only when a verification pass actually runs, not when the site rebuilds.

Are you an obligated producer?

Seven questions, then a per-state read with the reason and the rule behind each answer. Built to settle the straightforward nine cases in ten and then name the qualifiers it could not resolve for you, rather than guessing. Every verdict shows whether the rule behind it was read in the primary text or rests on an official but non-final source. A screening aid, not legal advice.

Prefer to read the rules rather than answer questions? Am I an Obligated Producer? works through the producer cascade in every state, and the de minimis thresholds page covers the exemption side.

Question 1
Which states do you sell into?
Include anything shipped to a customer in that state, direct or through a retailer or marketplace.
Question 2
Which best describes your role?
Pick the one closest to how your packaged goods reach the market.
Question 3
Company-wide gross revenue, last calendar year
Total revenue for the whole organization, not revenue in any single state. This distinction decides the answer more often than any other input, and it is the one most often got wrong.
Question 5
Do any of these describe you?
Several states exempt specific organization types outright. Tick all that apply.
Question 6
Do you sell only to business customers?
Business-to-business only, with no consumer sales in these states.
Question 7
What kinds of packaging do you put on the market?
Several states run separate producer rules for particular packaging types that override the general answer. Tick all that apply.
This screener describes the general rules and does not apply them to your specific facts. It produces a starting point, not a compliance determination, and it creates no advisory or attorney relationship. Verify with the Circular Action Alliance, the relevant state agency, or qualified counsel before acting, or before deciding not to act. Full terms of use.

How packaging EPR scope actually works

Three separate tests decide whether a company has an EPR obligation in a given state, and all three have to point the same way before you are in scope.

The screener above walks these three tests state by state and returns a per-state read. For the rules themselves, written out state by state rather than applied to your answers, see Am I an Obligated Producer?. For the exact thresholds see the de minimis thresholds comparison, and for the underlying statutes see EPR laws by state.

Frequently asked questions

How does the screener decide whether I am in scope?
In most enacted states the obligated producer is the brand owner whose brand appears on the covered product. If the brand owner has no U.S. presence, the obligation moves to the importer of record, and if neither exists, to the distributor or retailer that first sells the item into the state. Store-brand and private-label goods make the retailer the producer. Licensed brands usually make the licensee the producer unless the licence assigns it otherwise. Revenue and tonnage de minimis thresholds then decide whether an otherwise obligated company actually has to register and report.
Does the screener give me a compliance determination?
No. The screener describes the general rules and does not apply them to your specific facts. It produces a starting point for a scoping conversation, not a compliance determination, and it creates no advisory or attorney relationship. Verify with the Circular Action Alliance, the relevant state agency or qualified counsel.
Which states does the scope screener cover?
All seven U.S. states with enacted packaging EPR laws: California, Colorado, Oregon, Maine, Minnesota, Maryland and Washington. Each state sets its own producer definition, de minimis thresholds and covered material scope, so a company can be obligated in one state and out of scope in another.
Are packaging suppliers obligated producers?
Usually not for the packaging they sell empty to another company. Obligation generally attaches to the party that places a packaged product on the state market under its own brand, not to the converter or component maker upstream. A supplier can still be obligated for its own branded goods and for any packaging it places on the market itself.