In Washington and Minnesota, the statutes set no date for producers to report supply data to the PRO, so the PRO’s dates apply (RCW 70A.208.040 and 70A.208.160(1); Minn. Stat. 115A.1448 and 115A.1454). Maryland’s rule leaves the date to the producer responsibility plan or a method MDE approves (COMAR 26.04.14.07A(2)), and the first plans are due
July 1, 2028 (Md. Code, Envir. 9-2505(b)(1)). California sets producer dates in regulation, and the PRO registers each participant producer with CalRecycle unless the producer chooses to report directly (14 CCR 18980.10(a)(2)). Colorado lets a producer use prorated national data when state-specific data is not available or feasible to generate (C.R.S. 25-17-708(1)), and its first supply report was due
July 31, 2025, more than four months before CDPHE approved the plan that states the date. CAA’s Reporting Policy (Version 2.0, June 2026) has a late registrant report and pay for prior periods with applicable interest.
What this means for you: in Washington and Minnesota, the reporting date you must meet comes from the PRO, and in Maryland from the plan or a method MDE approves, so watch CAA’s notices; in California, a participant that chooses to report directly must register itself with CalRecycle (14 CCR 18980.1(a)(22), 18980.10(a)(2)).
Sources:
Chapter 70A.208 RCW;
Minn. Stat. 115A.1448;
COMAR 26.04.14.07;
Md. Code, Envir. 9-2505;
14 CCR 18980.10;
HB 22-1355 (C.R.S. 25-17-708);
CDPHE release (December 10, 2025);
CAA Reporting Policy, Version 2.0.