Maine, Oregon, and Colorado EPR Laws Compared: Fees, Timelines, and Compliance Strategies
A side-by-side comparison of the three pioneering US state EPR programs and what multi-state compliance looks like in practice.
By Packgine
January 5, 2026
With California's SB 54 dominating headlines, the EPR programs in Maine, Oregon, and Colorado are sometimes overlooked—but for companies already selling into these states, compliance is not optional. Each state has taken a distinct approach to EPR implementation, creating both challenges and opportunities for brands navigating multi-state compliance.
Maine: LD 1541 — The Pioneer
Maine made history as the first US state to enact EPR legislation for packaging in July 2021. The law reflects Maine's pragmatic, community-focused approach to waste management.
Program Structure Maine's program requires producers to join a stewardship organization that manages packaging collection and recycling on behalf of all participating producers. Unlike some European models where multiple PROs compete, Maine's law envisions a single stewardship organization to ensure statewide coverage—particularly important in a rural state where collection efficiency depends on comprehensive geographic coverage.
Fee Structure Maine's fee system is designed around a simple principle: the harder your packaging is to recycle in Maine, the more you pay. Packaging accepted in Maine's curbside recycling programs: lower fee tier. Packaging accepted at drop-off locations but not curbside: middle fee tier. Packaging not accepted in any Maine recycling program: highest fee tier.
Preliminary fee estimates range from $50 to $150 per tonne for easily recyclable materials and $300 to $800 per tonne for difficult-to-recycle packaging. The stewardship organization will set final fees based on actual program costs.
Municipal Reimbursement A unique feature of Maine's law is its emphasis on reimbursing municipalities for packaging recycling costs they currently bear. The program is designed to shift these costs entirely from taxpayers to producers over a five-year transition period. Municipalities will receive reimbursement based on the quantity and type of packaging they collect and process.
Key Timelines 2021: Law enacted. 2023: Stewardship organization formation deadline. 2024: Initial producer registration and fee assessment. 2026: Full program implementation, including municipal reimbursement. 2028: First performance evaluation.
Cost Impact For a company placing 100 tonnes of packaging into Maine annually: estimated EPR fees of $8,000–$40,000 per year, plus $3,000–$8,000 in registration and compliance management costs. Total: $11,000–$48,000 annually.
Oregon: SB 582 — The Comprehensive Approach
Oregon's Plastic Pollution and Recycling Modernization Act, enacted in August 2021, takes the most comprehensive approach of any US state EPR program.
Program Structure Oregon's program is managed by a PRO that must develop and implement a comprehensive plan addressing the entire packaging lifecycle. The plan must include a statewide needs assessment identifying gaps in recycling infrastructure, a funding mechanism to close those gaps, collection programs ensuring convenient access for all Oregonians, and processing and end-market development for collected materials.
Oregon's Department of Environmental Quality (DEQ) has significant oversight authority, including the power to approve or reject the PRO's program plan and set performance targets.
Fee Structure Oregon's fee system is the most nuanced of the three states. Fees are based on three factors: packaging material type and weight, recyclability in Oregon's specific infrastructure, and the producer's market share of total packaging placed in Oregon.
Base fee ranges (estimated): Paper/cardboard: $60–$100 per tonne. Glass: $40–$80 per tonne. Aluminum: $80–$150 per tonne. PET: $200–$400 per tonne. HDPE: $180–$350 per tonne. Other plastics: $400–$900 per tonne. Multi-material/composite: $500–$1,200 per tonne.
Eco-modulation: Oregon's law requires fees to be modulated based on recyclability. Materials accepted in Oregon's recycling infrastructure receive the base rate, while materials not accepted pay a surcharge of 50–200% above the base rate. This creates a strong financial incentive for producers to use materials that Oregon can actually recycle.
Recycling List Oregon maintains an official "recycling acceptance list" that determines which materials are considered recyclable for fee modulation purposes. The list is updated every two years based on actual sorting and processing capabilities in the state. Materials not on the list are classified as non-recyclable and pay higher fees—regardless of whether they might be recyclable in other jurisdictions.
Key Timelines 2021: Law enacted. 2023: PRO formation and preliminary needs assessment. 2024: Needs assessment completed, program plan development begins. 2025: Program plan submitted to DEQ for approval. 2026: Fee collection begins, initial infrastructure investments. 2028: First performance evaluation against recycling rate targets.
Cost Impact For a company placing 100 tonnes of packaging into Oregon annually: estimated EPR fees of $15,000–$60,000 per year, plus $5,000–$12,000 in compliance management costs. Total: $20,000–$72,000 annually.
Colorado: HB 22-1355 — The Equity Focus
Colorado's Producer Responsibility Program for Statewide Recycling, enacted in June 2022, distinguishes itself through its strong emphasis on equity and universal access.
Program Structure Colorado's law requires the PRO to ensure that every Colorado resident has convenient access to recycling services—including residents in rural mountain communities, tribal lands, and underserved urban areas that currently lack recycling infrastructure. This equity mandate significantly shapes the program's cost structure and implementation approach.
The program includes an advisory board with representation from environmental justice communities, rural local governments, small businesses, and recycling industry participants. This ensures diverse stakeholder input in program design and implementation.
Fee Structure Colorado's fee structure incorporates equity considerations alongside recyclability. Fees fund not only the direct costs of packaging collection and recycling but also infrastructure development in underserved areas, education and outreach programs targeting communities with low recycling participation, and technical assistance for small businesses and rural communities.
Estimated fee ranges: Paper/cardboard: $50–$90 per tonne. Glass: $35–$70 per tonne. Easily recyclable plastics (PET, HDPE): $200–$400 per tonne. Other plastics: $350–$800 per tonne. Metals: $60–$140 per tonne.
Colorado has also established a "producer responsibility dues" structure that scales with company size, providing some relief for small producers.
Key Timelines 2022: Law enacted. 2024: PRO formation and needs assessment. 2025: Program plan development, stakeholder engagement. 2026: Fee collection begins, initial infrastructure investments. 2027: First performance review.
Cost Impact For a company placing 100 tonnes of packaging into Colorado annually: estimated EPR fees of $10,000–$45,000 per year, plus $4,000–$10,000 in compliance management costs. Total: $14,000–$55,000 annually.
Multi-State Compliance: The Real Challenge
Aggregated Cost Example A mid-sized consumer goods company selling into all three states (plus California) with 200 tonnes of total packaging might face:
Maine: $16,000–$80,000. Oregon: $30,000–$120,000. Colorado: $20,000–$90,000. California: $50,000–$500,000. **Total EPR fees: $116,000–$790,000 per year.**
Plus compliance management across all states: $25,000–$75,000 per year. Total annual cost: $141,000–$865,000.
Compliance Complexity Beyond fees, multi-state compliance creates operational complexity because each state defines "recyclable" differently. Each state has different reporting formats, deadlines, and data requirements. Fee structures vary, meaning the same packaging may cost very different amounts in each state. Audit requirements and enforcement approaches differ.
Companies need either dedicated compliance staff or a compliance platform that can manage requirements across all jurisdictions simultaneously. Manual management of multi-state EPR compliance is increasingly untenable as more states adopt EPR laws.
Harmonization Efforts Industry groups are advocating for greater harmonization across state EPR programs—standardized reporting formats, aligned definitions of recyclability, and common fee methodologies. While some progress has been made, significant differences are likely to persist for years.
Strategic Recommendations
For companies in one or two EPR states: Build compliance processes that can scale. The number of EPR states is growing rapidly, and investing in scalable infrastructure now will save significant costs later.
For multi-state companies: Invest in compliance software that manages requirements across all jurisdictions from a single platform. The cost of the software ($20,000–$75,000 per year) is typically a fraction of the cost of manual compliance management.
For all companies: Design packaging to the highest recyclability standards. Packaging that meets Oregon's strict recyclability definitions will generally satisfy requirements in Maine, Colorado, and California—while also minimizing EPR fees across all states.
The companies that develop robust, scalable EPR compliance capabilities now will be best positioned as EPR becomes the norm across the United States.
How Packgine Helps
Packgine is built for multi-state EPR complexity. One platform manages compliance across Maine, Oregon, Colorado, California, and every new state program as it launches.
EPR & PPWR Compliance Automation: Packgine tracks the unique requirements of each state's EPR program—different definitions of recyclability, different reporting formats, different deadlines, different fee structures. Automated filings and centralized dashboards replace the chaos of managing each state separately.
Compliance Cost Estimating: Model your total EPR cost across all states simultaneously. Packgine shows you how packaging changes affect fees in every jurisdiction at once—so you can make design decisions that optimize costs across your entire US footprint.
Alternative Product Suggestions: Packgine recommends packaging designs that satisfy the strictest state requirements (typically Oregon's recyclability definitions) while minimizing fees across all states. Each recommendation includes a state-by-state fee impact analysis, so you know exactly how much you'll save in Maine, Oregon, Colorado, and California.
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