Maryland EPR (SB 901): What to Do After the May 31 Deadline

Maryland enacted its packaging Extended Producer Responsibility law, Senate Bill 901, on May 13, 2025. Circular Action Alliance (CAA) is the approved producer responsibility organization for Maryland's packaging and paper products program, created by SB 901 in 2025. CAA's first approval as Maryland's single PRO in October 2023 was under SB 222 (2023), which established a producer responsibility advisory council and a statewide recycling needs assessment, not an operating EPR program. Maryland's program rules became effective May 25, 2026. Producers were required to register with CAA by May 31, 2026, and CAA was required to submit a full producer and brand list to the Maryland Department of the Environment (MDE) by July 1, 2026. Producers were also required to provide simplified reporting to CAA by May 31, 2026, with annual reporting thereafter.

As of August 22, 2026, both deadlines have passed. Producers who have not yet registered should register with CAA immediately to limit further exposure and prepare for annual reporting. Maryland's producer responsibility plan is due to MDE on or before 1 July 2028 under § 9-2505(B)(1). MDE then has 120 days to act on it under § 9-2505(H)(1), and implementation begins no later than 6 months after approval under § 9-2505(I). The approved plan sets the fee schedule, so no producer fee date exists yet. Reimbursement to local government service providers runs on at least a quarterly basis under the approved plan, and the statute sets minimum rates rather than a start date: at least 50% of the cost per ton on or before 1 July 2028, at least 75% on or before 1 July 2029, and at least 90% on or before 1 July 2030 and each year thereafter.

This post covers who must register, what simplified reporting requires, what late producers should do now, and what the next milestones are.

What happened on May 31, 2026

May 31, 2026 was the deadline for two separate obligations under Maryland's SB 901 program:

1. Producer registration with CAA. Producers selling covered packaging into Maryland had to register with Circular Action Alliance, Maryland's designated PRO. 2. Simplified reporting. Registered and unregistered producers were required to provide simplified packaging data to CAA for the initial compliance period.

CAA is the approved PRO for Maryland's packaging and paper products program, created by SB 901 in 2025. The program rules became effective May 25, 2026, giving producers six days to complete registration before the May 31 deadline.

What CAA submitted to MDE on July 1, 2026

By July 1, 2026, CAA was required to submit a complete producer and brand list to MDE. This submission documented which producers and brands had registered, which had reported, and provided the foundation for MDE's enforcement and program-planning work.

Who must register with CAA

Maryland's producer hierarchy under SB 901 follows the same pattern as other US programs:

1. The brand owner with US operations. 2. If no US brand owner, the importer of record. 3. If neither, the distributor or seller first placing goods on the Maryland market.

Marketplaces and online platforms can be deemed producers when no upstream entity qualifies. Small-producer thresholds apply; confirm your status against MDE's published guidance and CAA's registration materials before assuming either producer status or exemption.

What to do if you missed the May 31 deadline

If you have not yet registered or submitted simplified reporting, the priority is to register with CAA immediately. Late registration limits further exposure and positions you for the annual reporting cycle. The longer you wait, the larger the compliance gap becomes.

After registering:

1. Assemble a complete brand list covering every brand and product line sold into Maryland, including private label. 2. Build SKU-level or component-level packaging data: material category, weight, recyclability classification, and PCR content. 3. Submit any overdue simplified reporting as directed by CAA. 4. Establish state attribution logic so Maryland-bound volume can be isolated from national shipment data. 5. Prepare an audit-ready file for every claim.

What Maryland covers

SB 901 covers packaging across all three layers plus certain paper products. Maryland scope is broadly comparable to Oregon and California, with Maryland-specific edge cases and exclusions published by MDE and CAA. Confirm your material classification against CAA's current schema rather than assuming it matches another state.

What happens next: fees and the 2028 plan

Maryland's producer responsibility plan is due to MDE on or before 1 July 2028 under § 9-2505(B)(1). MDE then has 120 days to act on it under § 9-2505(H)(1), and implementation begins no later than 6 months after approval under § 9-2505(I). The approved plan sets the fee schedule, so no producer fee date exists yet. Reimbursement to local government service providers runs on at least a quarterly basis under the approved plan, and the statute sets minimum rates rather than a start date: at least 50% of the cost per ton on or before 1 July 2028, at least 75% on or before 1 July 2029, and at least 90% on or before 1 July 2030 and each year thereafter. The plan will define long-term collection targets, fee modulation, and infrastructure investment. Producers should expect annual reporting to continue on a cycle set by CAA and MDE.

Where first-cycle filings go wrong

Three failure modes recur across states. The wrong producer entity registers when the covered producer is a different entity in the corporate structure, which is paperwork-intensive to unwind. Brand lists miss smaller and private-label SKUs that then have to be added in true-ups. And internal terminology such as "stand-up pouch" gets mapped to the wrong material category, underpricing the fee model and forcing reconciliation later.

Multi-state context

If you are already registered with CAA for California, Oregon, Colorado, or Minnesota, Maryland registration is an extension of an existing membership rather than a fresh PRO setup. The data work is incremental. Keep one consolidated SKU-level dataset and map Maryland's specific fields to it.

For the broader picture, see EPR Laws in the US: State Regulations 2026 and 8-Step Packaging Compliance Plan.

Sources and citations

• Maryland Department of the Environment (MDE) published SB 901 guidance and program status.
• Circular Action Alliance, Maryland PRO: circularactionalliance.org/maryland.
• Confirm current deadlines and submission requirements directly with CAA and MDE before planning.

How Packgine helps

Your team can use the SKU-level packaging dataset Packgine maintains in a state-agnostic model for Maryland registration, late reporting, and annual submissions. Teams map the existing data for those tasks rather than starting a new data project. The same dataset feeds California, Oregon, Colorado, Minnesota, Maine, and Washington today.

Related reading

• Seven US States with Active Packaging EPR in 2026: A Status Map

• US State EPR Programs Compared: Fees, Deadlines, and Reporting Rules Side by Side

• The Packaging Data Model: What Fields You Actually Need at SKU and Component Level

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