Packaging EPR Update: Week of June 22, 2026

Everything that changed in U.S. packaging EPR in the week of June 22, 2026, 3 regulatory and policy changes. Regulatory and policy changes first, site updates after.

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What changed in the week of June 22, 2026

3 regulatory and policy changes. Everything below was checked against a primary source before publication. Entries carry the state or jurisdiction affected and the source that supports them.

Regulatory and policy

Litigation  |  CA, 17 STATES
17-State Coalition and NAW File Federal Challenge to California SB 54
On June 22, 2026 a coalition of 17 state attorneys general led by Nebraska, joined by the National Association of Wholesaler-Distributors as the sole business plaintiff, filed a federal lawsuit in the U.S. District Court for the Eastern District of California challenging SB 54, California's packaging EPR and source-reduction law. The complaint names CalRecycle Director Zoe Heller and the Circular Action Alliance as defendants and alleges violations of the dormant Commerce Clause and the First Amendment under the U.S. and California constitutions; plaintiffs seek to enjoin enforcement of SB 54 while the case proceeds. The joining states are Alabama, Florida, Georgia, Idaho, Indiana, Iowa, Louisiana, Missouri, Montana, Nebraska, North Dakota, Oklahoma, South Carolina, South Dakota, Texas, Utah, and West Virginia. Source: Packaging Dive; Waste Dive; Recycling Today (June 2026).
Update  |  ME
Maine DEP Issues Stewardship Organization RFP; Program Implementation Advances
Maine DEP issued its Request for Proposals to select a Stewardship Organization (Maine uses the term SO, not PRO) on June 15, 2026; the Circular Action Alliance has said it intends to respond. DEP also plans to publish producer guidance in summer 2026. Startup registration fees remain contingent on a signed SO contract and are due no more than 180 days after that contract's effective date. Source: Sustainable Packaging Coalition (June 22, 2026); Waste Dive; Packaging Dive (June 2026).
Litigation  |  CO
Colorado CDPHE Moves to Dismiss ILMA Challenge to Packaging EPR Program
In ILMA v. CDPHE (Denver District Court No. 2026CV30902, filed March 12, 2026), the Colorado Department of Public Health and Environment has moved to dismiss the Independent Lubricant Manufacturers Association's challenge to the state's packaging EPR program; the motion was pending as of early June 2026. CDPHE argues the statutory claims are untimely under the Administrative Procedure Act's 35-day judicial review window, that the due process, nondelegation, and First Amendment claims fail on the merits, and that the Circular Action Alliance and the Lubricants Packaging Management Association are necessary parties. ILMA did not seek a preliminary injunction, so the program remains in effect. Source: Arnold and Porter (June 1, 2026); Foley and Lardner (April 6, 2026).