California: SB 54 (PRC 42061.5)
SB 54 sets the most demanding source-reduction and recycling-rate mandates of any US packaging EPR law. Circular Action Alliance issues the first fee invoices in January 2027.
Packaging extended producer responsibility in the United States is built state by state. Each program defines its own covered materials, reporting units, fee schedule and deadlines, so a single national tonnage figure cannot satisfy any of them. What travels between states is the underlying data: component-level packaging records joined to state-resolved sales.
Start with the states you sell into, then check what is coming on the compliance calendar.
Seven states have enacted packaging EPR. Every cell is taken from the linked state page or the compliance calendar, and matches the same table on the EPR hub.
| State | Statute | Producer registration deadline | First report due | PRO |
|---|---|---|---|---|
| California | SB 54 (PRC 42061.5) | Producer registration/participation with CAA by June 1, 2026 (passed) | 2023 baseline and 2025 annual supply reports due May 31, 2026 (passed) | Circular Action Alliance |
| Colorado | HB 22-1355 | Registration via CAA; 2026 dues period opened January 2026 | Initial participation and reporting by July 31, 2025 (passed); annual CAA reporting due May 31, 2026 | Circular Action Alliance |
| Maine | LD 1541 | Not yet open: Maine DEP is revising its stewardship organization RFP | Not yet set | Not yet contracted |
| Maryland | SB 901 | CAA intake May 31, 2026 (passed); individual-plan producers register directly with MDE from July 1, 2026 | CAA simplified supply report May 31, 2026 (passed) | Circular Action Alliance |
| Minnesota | Minn. Stat. § 115A.1448 | July 1, 2025: producers must be a member of a registered PRO (§ 115A.1448(a)) | TBD by rulemaking | Registered PRO under § 115A.1448 |
| Oregon | SB 582 (Recycling Modernization Act) | PRO membership required; PRO membership fees began July 2025 | May 31, 2026 (annual reporting) | Circular Action Alliance |
| Washington | E2SSB 5284 (RCW 70A.208) | July 1, 2026 (passed) | TBD: needs assessment, program plan and full implementation expected 2028 to 2030 | Circular Action Alliance (only registered PRO) |
SB 54 sets the most demanding source-reduction and recycling-rate mandates of any US packaging EPR law. Circular Action Alliance issues the first fee invoices in January 2027.
Colorado's Producer Responsibility for Recycling Act is overseen by CDPHE and administered by Circular Action Alliance. The 2026 dues period opened in January 2026 and the annual producer supply report for the 2027 program year was due to CAA on May 31, 2026.
Maine enacted the first US packaging EPR law in July 2021, but the program is not operating. Its stewardship organization RFP closed on August 20, 2026 with no proposals submitted, so there is no registration route and no fee clock.
Maryland enacted SB 901 on May 13, 2025 and its program rules became effective May 25, 2026. CAA set a May 31, 2026 intake date for producer registration and simplified supply reports, then filed the producer, brand and material lists with MDE by July 1, 2026. Individual-plan producers register directly with MDE.
Minnesota's 2024 law requires producers to be a member of a registered PRO since July 1, 2025. Fees are governed by Minn. Stat. § 115A.1454, and a producer is de minimis under § 115A.1441 subd. 13 below one ton into Minnesota or $2,000,000 global gross revenue.
Oregon was the first US program to reach live producer reporting. DEQ administers the Recycling Modernization Act, PRO membership fees began in July 2025, and annual reporting was due May 31, 2026.
Washington's Recycling Reform Act required producers to be a member of a registered PRO, or to register as a PRO implementing an individual plan, after July 1, 2026. Circular Action Alliance is the only registered PRO in the state.
Packaging reduction and recycled content requirements alongside producer responsibility.
Proposed packaging reduction and recycling legislation to watch, not yet an operating program.
Producers register with the state's producer responsibility organisation, in most states Circular Action Alliance, then report covered packaging weight and pay fees that fund collection and recycling. Fee schedules are moving toward eco-modulation, which prices recyclability rather than tonnage alone.
Check whether you are obligated with the EPR obligation checker, estimate cost with the EPR fee calculator, and read the EPR automation overview for how the reporting workflow fits together. Selling abroad too? See the EU hub and the UK hub.
No. Packaging EPR in the United States is enacted state by state, so scope, covered materials, reporting units, fee schedules and deadlines all differ. There is no single national filing.
You register with the producer responsibility organisation operating in each state. Most states have selected Circular Action Alliance, which gives a shared account, but the underlying data must still be resolved state by state.
Packaging weight by covered material category, attributable to sales into that state. That requires component-level packaging records joined to state-resolved sales volumes, not national totals.
Most states set de minimis thresholds by revenue or tonnage, but the thresholds differ and some exemptions cover fees only, leaving a registration or reporting duty in place.
Packgine keeps one packaging dataset and produces each state's report, fee forecast and audit trail from it.