MDE has posted a 36-page
Compliance Guide with FAQs for COMAR 26.04.14, marked “Rev 1, September 2026”, which supersedes a June 2026 version of the same document. It is guidance rather than new law, and it carries its own caveat that it “is subject to change”.
It also states the registration duty more loosely than the regulation does. The guide put the July 2026 registration on every producer distributing covered materials into Maryland. COMAR 26.04.14.07A(1) put that filing on the PRO and on producers taking the Individual Producer Plan route; a PRO member sends brands, covered-material weights and fee
to its PRO, on the date the PRO sets (.07A(2)). The guide itself says the same thing four pages later. Where the two disagree, the regulation governs.
Three dates the guide states plainly and that are now on this site: the recurring annual registration deadline is
June 30 from 2027 on, not July 1;
IPPs are due July 1, 2028; and from
October 29, 2028 no producer may sell, offer for sale, distribute or import covered materials in Maryland without a Department-approved responsibility plan on file. An annual registration fee is payable to MDE and no amount is published, but COMAR 26.04.14.07C(2) caps what a PRO may charge its members collectively at what the PRO itself pays MDE.
What this means for you: if you are a CAA member, nothing changes today. You report to CAA on CAA’s date and CAA files with MDE. If you are considering an Individual Producer Plan, the guide is the first plain-language statement of that path and the October 2028 date is the one to diary. Source:
Maryland Department of the Environment, COMAR 26.04.14 Compliance Guide with FAQs (Rev 1, September 2026).