Maryland enacted its packaging Extended Producer Responsibility law, Senate Bill 901, on May 13, 2025. Circular Action Alliance (CAA) has served as Maryland's Producer Responsibility Organization since October 2023 (initially under precursor legislation, reaffirmed under SB 901). Maryland's program rules became effective May 25, 2026. Producers were required to register with CAA by May 31, 2026, and provide simplified reporting by the same date. CAA submitted a full producer and brand list to the Maryland Department of the Environment (MDE) by July 1, 2026. 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. Fee collection is expected to begin ahead of formal reimbursement starting July 1, 2028, when Maryland's Producer Responsibility Plan is also due to MDE. Covered material scope is expected to closely resemble Oregon's and California's, with eco-modulated fees based on material type, recyclability, and recycled content. Confirm all specifics against MDE and CAA's published guidance.
By Kevin Kai Wong, Managing Partner, gCurv Technologies
Packgine automates Maryland EPR readiness, PRO selection analysis, data reporting, and fee modeling alongside all other US and EU obligations.
Producers were required to register with CAA and provide simplified reporting by May 31, 2026. Late producers should register immediately to limit further exposure.
CAA has served as Maryland's PRO since October 2023, reaffirmed under SB 901. Registering with CAA is the current compliance pathway.
Fees are adjusted based on packaging material recyclability, recycled content percentage, and environmental performance metrics.
Report packaging material type, weight, units sold in Maryland, recyclability classification, and recycled content data annually.
Packaging formats must meet Maryland's recyclability standards, with fee incentives for packaging that meets or exceeds benchmarks.
Maryland's enforcement regime includes civil penalties for non-registration, missed reporting deadlines, and ongoing non-compliance.
Maryland's packaging EPR law is Senate Bill 901, signed on May 13, 2025. Circular Action Alliance (CAA) has served as Maryland's Producer Responsibility Organization since October 2023, initially under precursor legislation and reaffirmed under SB 901. The program rules became effective May 25, 2026, and producers were required to register with CAA and provide simplified reporting by May 31, 2026. CAA submitted a full producer and brand list to the Maryland Department of the Environment (MDE) by July 1, 2026. 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.
Fee collection is expected to begin ahead of formal reimbursement starting July 1, 2028, when Maryland's Producer Responsibility Plan is also due to MDE. 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.
Maryland applies the standard hierarchy: the brand owner with US operations first, then the importer of record where no US brand owner exists, then the distributor or seller first placing goods on the Maryland market. Marketplaces and online platforms can be deemed producers when no upstream entity qualifies, and small-producer thresholds apply. Covered material is expected to span all three packaging layers plus certain paper products, broadly comparable to Oregon and California scope, with Maryland-specific edge cases to confirm against CAA's current schema.
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. Producers already registered with CAA for California, Colorado, Minnesota, or Oregon can extend that membership to Maryland, so the data work is incremental rather than duplicative.
Every Packgine article covering Maryland packaging rules, from producer scope to reporting mechanics.
With CAA as Maryland's designated PRO, Maryland is best read alongside the active US EPR program map to understand which parts of your compliance process carry over from other CAA states and which are Maryland specific.
The closest peers are Minnesota's producer definition, which captures a similar set of obligated companies, and Washington's registration window, which follows the same registration-first sequencing.
Check upcoming EPR registration deadlines for the states still open, and pull packaging data straight from your ERP so Maryland reporting does not depend on manual spreadsheets.
Determines producer coverage status based on Maryland market sales and distribution data
Analyzes multiple PRO options to help producers evaluate fee structures and services
Tracks Maryland implementation milestones as MDE publishes needs assessment, PRO designation, and plan approval steps
Maps SKU-level packaging data to Maryland's material classification framework
Calculates projected fees across different PRO scenarios for cost optimization
Generates Maryland-formatted compliance reports for PRO or individual plan submission
Maryland's SB 901 program became effective May 25, 2026, with producer registration and simplified reporting due May 31, 2026. Circular Action Alliance (CAA) has been the PRO since October 2023, so the pathway is a single PRO registration rather than a multi-PRO selection process at launch. Packgine helps producers register late and prepare annual reporting.
The registration deadline was May 31, 2026. CAA submitted a full producer and brand list to MDE by July 1, 2026. As of August 22, 2026, both deadlines have passed. Producers who have not yet registered should register with CAA immediately to limit further exposure.
Maryland uses a responsible-party hierarchy. The brand owner is generally first-obligated; if the brand owner has no US presence, the obligation falls to the importer. Retailers and distributors are generally NOT the obligated producer unless they own the brand (e.g., private label) or are the first importer of packaged consumer products sold in Maryland.
Maryland allows producers to comply either through an approved producer responsibility organization or by filing an Individual Producer Responsibility Plan directly with the Department. Circular Action Alliance is currently the only approved PRO in Maryland. A feature genuinely distinctive to Maryland is its franchise rule at COMAR 26.04.14.02B(25)(g), which makes the franchisor the producer where its franchisees have a commercial presence in the state.
Yes. Packgine manages Maryland EPR simultaneously with all other active US state programs and EU requirements from one dashboard, with no additional configuration needed.
Content reviewed by Kevin Kai Wong, Managing Partner at gCurv Technologies
Register, report, and manage Maryland packaging EPR alongside all other jurisdictions from a single platform.