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Extended Producer Responsibility (EPR) Laws in the US

EPR regulations explained: implementation timelines, reporting requirements, penalties, and next steps for producers.

Across the United States, Extended Producer Responsibility (EPR) laws for packaging are moving from legislation into implementation, reshaping how organizations produce, manage, and report on packaging materials. Seven states have enacted comprehensive packaging EPR laws, with programs at different stages of implementation.

What are EPR laws?

At its core, EPR places greater responsibility on producers for the lifecycle of products and packaging, including how materials are collected, recycled, and managed at end of life.

Rather than placing the cost of waste management primarily on taxpayers and local governments, EPR programs require covered producers to help fund and manage recycling systems. Requirements vary by state but can include producer registration, participation in a Producer Responsibility Organization (PRO), packaging data reporting, fees, and ongoing compliance obligations.

State by state look at current EPR regulations

California

Law: Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54)
Enacted: June 2022
Producer Responsibility Organization (PRO): Circular Action Alliance (CAA)
Implementation status: California's implementing regulations took effect May 1, 2026. Initial producer registration, reporting, and early implementation requirements began in 2026 as the state continues toward broader program implementation.
Penalties: Noncompliant producers may face administrative penalties and enforcement actions under SB 54.
Potential fines: California authorizes penalties of up to $50,000 per day per violation, with provisions affecting how and when penalties accrue.
Notes:
- California's program continues to move through implementation, making it important for producers to monitor guidance from CalRecycle and CAA.
- Organizations should continue assessing their reporting, packaging data, and fee obligations as requirements take effect.

Colorado

Law: Producer Responsibility Program for Statewide Recycling Act (HB 22-1355)
Enacted: 2022
PRO: CAA
Implementation status: Producer registration and reporting requirements are in effect, and the program has moved into its fee implementation phase.
Penalties: Producers that do not meet applicable registration, reporting, or payment requirements may be subject to enforcement.
Potential fines: Colorado's law provides for penalties for violations, making ongoing compliance important as the program moves further into implementation.
Notes:
- The program establishes producer responsibility for funding improvements to Colorado's recycling system.
- Producers should continue monitoring CAA and state guidance for reporting and fee requirements.

Maine

Law: Stewardship Program for Packaging (SPP)
Enacted: 2021
Implementation status: Maine's packaging stewardship program continues to move through implementation. Unlike several other states, its program structure differs significantly, so producers should monitor the Maine Department of Environmental Protection for current implementation requirements.
Penalties: Failure to meet applicable requirements under Maine's packaging stewardship law can result in state enforcement.
Potential fines: Penalties may apply for noncompliance, with the amount dependent on the nature and duration of a violation.
Notes:
- Maine was the first US state to enact an EPR law for packaging.
- Its approach differs from programs administered through CAA in other states, making state-specific monitoring particularly important. Current 2026 trackers note that Maine remains at a different implementation stage from the other six states.

Maryland

Law: Packaging Producer Responsibility Act (SB 901)
Enacted: May 13, 2025
PRO: CAA is an approved PRO
Implementation status: Producer PRO participation requirements began in 2026, while additional requirements will be phased in as Maryland develops its packaging EPR program. CAA identifies Maryland as one of the states in which it currently administers EPR programs.
Penalties: Noncompliance with applicable requirements may result in enforcement and financial penalties.
Potential fines: Penalties can vary depending on the violation and applicable provisions of the law.
Notes:
- Maryland allows for multiple PROs under its program structure.
- Organizations should track implementation milestones as reporting and producer responsibility requirements continue to develop.

Minnesota

Law: Packaging Waste and Cost Reduction Act (HF 3911)
Enacted: May 2024
PRO: CAA
Implementation status: Producer registration requirements are in effect, while additional program requirements continue to be phased in.
Penalties: The Minnesota Pollution Control Agency can impose penalties for violations of applicable EPR requirements.
Potential fines: Minnesota's penalty structure can reach $25,000 per day for an initial violation, with higher statutory tiers for repeat violations under specified circumstances.
Notes:
- Minnesota's requirements will continue to evolve as the state's program moves toward full implementation.
- Producers should monitor CAA and Minnesota Pollution Control Agency guidance to understand their obligations.

Oregon

Law: Plastic Pollution and Recycling Modernization Act
Enacted: 2021
PRO: CAA
Implementation status: Oregon's program is operational, with producer reporting, registration, and fee requirements in effect. Oregon was among the first states to move packaging EPR from legislation into active program implementation.
Penalties: Producers that fail to meet applicable registration, reporting, or payment requirements may be subject to enforcement by the Oregon Department of Environmental Quality.
Potential fines: Oregon can impose penalties of up to $25,000 per day for violations.
Notes:
- The Act covers packaging, paper, and food serviceware.
- With the program now operational, businesses placing covered products into the Oregon market should make ongoing compliance part of their regular reporting and packaging-data processes.

Washington

Law: Recycling Reform Act (SB 5284)
Enacted: May 17, 2025
PRO: CAA
Implementation status: Producer PRO participation requirements have taken effect, with additional elements of Washington's program being phased in over time. CAA now identifies Washington among the states where it administers EPR programs.
Penalties: Producers that do not meet applicable participation, reporting, or other compliance requirements may be subject to enforcement.
Potential fines: Financial penalties may apply depending on the nature and duration of the violation.
Notes:
- Washington was the seventh state to enact comprehensive packaging EPR legislation.
- Producers should continue monitoring state and CAA guidance as implementation progresses.

For US organizations and companies doing business across multiple states, this growing patchwork of requirements means compliance can look different depending on where products are sold and what packaging materials they contain.

Importantly, EPR should no longer be viewed solely as a future regulatory issue. Registration, reporting, PRO participation, and fee obligations are already in effect in several states.

How to prepare for EPR

Organizations can reduce compliance and reputational risks by proactively adapting their operations:

Assign clear responsibility for EPR compliance and reporting across the organization.
Track obligations by jurisdiction, including registration, reporting, fee, and material requirements.
Strengthen data systems to capture accurate information on packaging weights, materials, and sales.
Evaluate packaging design to identify opportunities to improve recyclability, reduce material use, and prepare for fee structures that may incentivize more sustainable packaging.
Collaborate with suppliers to obtain the packaging specifications and data needed to meet reporting requirements.
Review compliance processes regularly as state regulations, PRO guidance, reporting requirements, and fees evolve.

CAA currently supports producers through a centralized Producer Portal and provides state-specific resources covering registration, reporting, and payment requirements.

What’s next?

EPR requirements are becoming an increasingly important part of the US regulatory landscape. As existing state programs mature and EPR policy continues to develop, organizations will need to adapt their packaging strategies, supply chain data, reporting systems, and compliance processes.

For producers operating across multiple states, the challenge is not simply meeting a single deadline. It is establishing a repeatable approach for identifying obligations, maintaining accurate packaging data, managing reporting, and responding as requirements change.

Taking action now can help organizations stay ahead of evolving requirements, reduce compliance exposure, and build packaging strategies that are better prepared for the future.

Learn more about EPR international frameworks and what they mean for global producers.

For more information on EPR, please read The New Waste Equation: How Extended Producer Responsibility is Reshaping Corporate Environmental Accountability.