Seven US States with Active Packaging EPR in 2026: A Status Map
By 2026, seven US states have active packaging EPR laws on the books. Here is a single-page status map of where each program stands, what producers must do, and how the obligations differ.
By Kevin Kai Wong, Managing Partner at gCurv Technologies
May 2, 202613 min read
Table of Contents
- 1.The seven states at a glance
- 2.California (SB 54)
- 3.Oregon (Plastic Pollution and Recycling Modernization Act)
- 4.Colorado (Producer Responsibility Program for Statewide Recycling)
- 5.Maine (LD 1541)
- 6.Minnesota (Packaging Waste and Cost Reduction Act)
- 7.Maryland (HB 254)
- 8.Washington (Recycling Reform Act)
- 9.What to do in 2026
- 10.How Packgine helps
- 11.Related reading
By 2026, seven US states have moved packaging Extended Producer Responsibility from concept to active obligation. For multi-state brands, the practical question is no longer whether EPR will arrive, but how to operate seven different programs from one packaging dataset.
This post is a single-page status map. For each of the seven states, it summarizes what the law requires, who counts as a producer, who runs the program, and what the 2026 status is. Specific dates and dollar figures change cycle to cycle and should be confirmed against the relevant agency or PRO before any planning is locked.
For the deeper jurisdiction-by-jurisdiction view, see EPR Laws in the US: State Regulations 2026.
The seven states at a glance
The seven states with active packaging EPR programs in 2026 are California, Oregon, Colorado, Maine, Minnesota, Maryland, and Washington. Each has its own statute, its own definitions, and its own implementation timeline, but most share a common operational shape: a Producer Responsibility Organization administers the program, producers register and submit packaging data, and fees fund collection and recycling infrastructure.
California (SB 54)
California's SB 54 is the largest US packaging EPR program by covered volume. The Circular Action Alliance is the approved PRO. Covered producers register, submit packaging data, and pay fees that fund the statewide plan. Material reduction, recyclability, and recycled content targets escalate over the life of the program.
For a focused walkthrough, see California SB 54: A Practical Guide for Producers.
Oregon (Plastic Pollution and Recycling Modernization Act)
Oregon was the first US state to bring a packaging EPR program live. CAA administers Oregon as well. The Oregon program emphasizes a defined list of covered materials, a fee schedule that varies by material, and integration with the existing Oregon recycling system.
Colorado (Producer Responsibility Program for Statewide Recycling)
Colorado's program, also administered by CAA, sets up a statewide recycling list and a fee model that funds expanded access. Producers register, report, and pay fees on covered packaging and paper products.
For Maine, Oregon, and Colorado side by side, see Maine, Oregon & Colorado EPR Compared.
Maine (LD 1541)
Maine's program is structurally distinct: it is a reimbursement model in which producers pay fees that reimburse municipalities for the cost of managing covered packaging waste. Maine is administered through a stewardship organization on a similar timeline to the other early states.
For mechanics, see Maine EPR Reimbursement Fee Mechanics.
Minnesota (Packaging Waste and Cost Reduction Act)
Minnesota's program brings packaging EPR to the Upper Midwest with CAA as the named PRO. Producers should expect a familiar registration and reporting cadence, with state-specific covered material lists and fee modulation.
Maryland (HB 254)
Maryland's program adds a Mid-Atlantic state to the active list. Producer registration and program build-out are the 2026 focal points. See Maryland EPR 2026: Producer Registration.
Washington (Recycling Reform Act)
Washington's program phases in producer obligations over time. See Washington State EPR Implementation Roadmap.
What to do in 2026
For multi-state producers, the operational priorities are consistent across all seven states:
1. Confirm producer status in each state and identify the registering legal entity. 2. Establish PRO membership where required, typically with Circular Action Alliance for most states. 3. Build one SKU-level packaging dataset that can feed all seven state submissions. 4. Validate material categories and recyclability classifications against each PRO's schema. 5. Build state-by-state fee models so finance can budget current and future cycles. 6. Stand up audit-ready documentation for recycled content and recyclability claims.
For a financial picture, see Multi-State EPR Cost Modeling: From $85K to $13M in Annual Exposure.
How Packgine helps
Packgine treats the seven states as one dataset, seven outputs. The same SKU-level packaging record drives California, Oregon, Colorado, Maine, Minnesota, Maryland, and Washington fee models, registration packages, and data submissions. Producers invest once in clean packaging data and reuse that investment for every state cycle.
Related reading
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