Guide
What is packaging EPR?
A plain-English guide for consumer brands. Last checked October 31, 2026.
The short answer
Packaging EPR (extended producer responsibility) laws make the brands that sell packaged products pay for recycling the packaging. In Oregon, Colorado, California, Washington, Minnesota and Maryland, covered producers join Circular Action Alliance (CAA), report the materials and weights of the packaging they sell into each state, and pay fees based on those reports.
Who counts as a producer?
Usually the brand owner of the packaged product. Where there is no brand owner in the state’s chain, the definitions move to the licensee, importer or first distributor, and retailers are producers for their private-label goods. Each state’s law defines it a little differently, and CAA publishes producer-definition guidance for each state. You decide whether you’re a producer, with your counsel if you like; our free EPR Check lays the rule text next to your figures.
Which states have programs?
Six states run packaging programs through Circular Action Alliance: Oregon, Colorado, California, Washington, Minnesota and Maryland. Maine has a law but no stewardship organization yet.
| State | Next report | Fees |
|---|---|---|
| Oregon | Annual supply report on 2026 data, due to CAA by May 31, 2027 | Invoiced by CAA; the 2026 report sets fees paid in January 2027 |
| Colorado | Annual supply report on 2026 data, due to CAA by May 31, 2027 | Dues to CAA from January 2026 |
| California | Annual reporting to CAA; 2027 date not yet published by CAA (as of October 31, 2026) | Fee obligations start January 2027; CAA must also pay $500 million a year into the state’s Plastic Pollution Mitigation Fund from 2027 through 2037 |
| Washington | Annual reporting to CAA; 2027 date not yet published by CAA (as of October 31, 2026) | CAA has published a 2027 early fee schedule |
| Minnesota | Annual reporting to CAA; 2027 date not yet published by CAA (as of October 31, 2026) | Producers fund at least 50% of covered costs from February 1, 2029, 75% from 2030 and 90% from 2031 |
| Maryland | Annually by May 31, per CAA | Producers start reimbursing collection and processing costs July 1, 2028; fee dates before that not yet set |
What does a producer have to do?
- Register with CAA and sign its Participant Producer Agreement.
- Collect supply data: the material and weight of each packaging component, times units sold into each state.
- Report each year in CAA’s Producer Portal, with a written methodology.
- Pay the fees or dues CAA invoices from those reports.
What does it cost?
CAA sets fees by material and weight, and publishes fee schedules for each state. Late payments carry a compounding monthly charge, and a late or inaccurate report can draw a CAA charge of up to $5,000, or more where the fees on the misreported material are higher.
Sources
General information, not legal advice. You decide whether you’re a producer.
Questions
Frequently asked
What is packaging EPR?
Packaging EPR (extended producer responsibility) laws make the brands that sell packaged products pay for recycling the packaging. In Oregon, Colorado, California, Washington, Minnesota and Maryland, covered producers join Circular Action Alliance (CAA), report the materials and weights of the packaging they sell into each state, and pay fees based on those reports.
Who counts as a producer?
Usually the brand owner of the packaged product. Where there is no brand owner in the state’s chain, the definitions move to the licensee, importer or first distributor, and retailers are producers for their private-label goods. Each state’s law defines it a little differently, and CAA publishes producer-definition guidance for each state. You decide whether you’re a producer, with your counsel if you like; our free EPR Check lays the rule text next to your figures.
Which states have packaging EPR programs?
Oregon, Colorado, California, Washington, Minnesota and Maryland run programs through Circular Action Alliance. Maine has a law but no stewardship organization yet.
When are reports due?
The 2026 producer reports were due to CAA on May 31, 2026 in all six states. Oregon and Colorado annual reports on 2026 data are due by May 31, 2027.
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