Registration dates, supply report deadlines, and fee start dates for every U.S. state with an enacted packaging EPR law. Reporting obligations begin before fees in several states.
This page is free to read and updated weekly, and the fee calculator needs a free EPR Atlas account.
Last updated October 25, 2026.
EPR reporting deadlines at a glance
The table gives each state's registration date, its first or recurring supply report date, and the date fees begin. Registration usually comes first or shares a deadline with the first report, and it can fall years before any fee is invoiced.
Mar 31, 2025: Producers, except small producers and producers that did not sell, offer for sale, or distribute covered products in or into Oregon in 2024, had to pre-register with a PRO and submit 2024 supply data by this date under OAR 340-090-0870. Missing it did not bar later registration. Failing to register with or become a member of a PRO is a Class I violation (OAR 340-012-0098(1)(a)).
Mar 31, 2025: CY2024 Annual Supply Report due under DEQ rule OAR 340-090-0870 (no statute sets the date); this is the report the 2026 fee invoices are calculated from
Jul 31, 2025: CY2024 Annual Supply Report (2024 supply data) due to CAA; producers had to register with CAA by Oct 1, 2024 and participate from Jul 1, 2025
Jul 31, 2025: CY2024 Annual Supply Report (2024 supply data) due to CAA; producers had to register with CAA by Oct 1, 2024 and participate from Jul 1, 2025
Jun 1, 2026: Producer registration deadline (PEPRS/CAA)
May 31, 2026: Three producer filings due to CAA: 2026 Baseline Producer Report (CY2023 data), Annual Supply Report (CY2025), Annual Source Reduction Report (CY2025). CAA's report-planning dates; the baseline supply data is due with the PRO application within 30 days after May 1 under 14 CCR 18980.5(b), (d), and CAA's May 2026 California guidance treats that deadline as June 1, 2026 because May 31 was a Sunday
2026 early fees invoiced from August 2026; program fees 2027 (post program plan approval)
Jul 1, 2026: PRO must register with the MPCA commissioner (115A.1443 Subd. 1(a)); producers had to appoint a PRO by Jan 1, 2025
May 31, 2026: Interim Producer Report (simplified reporting categories) due (CAA-set date, not statutory)
No producer fee start date set; the first reimbursement floor is Feb 1, 2029 (50% of net costs, 115A.1455 subd. 4), and the PRO may charge member fees earlier (115A.1443 subd. 3(c))
May 31, 2026: Producer registration with CAA and simplified reporting to CAA due (CAA-set date); COMAR 26.04.14 fixes no May 31 date
May 31, 2026: Producer registration with CAA and simplified reporting to CAA due (CAA-set date); COMAR 26.04.14 fixes no May 31 date
No producer fee start date set; the first reimbursement floor is Jul 1, 2028 (Md. Envir. 9-2505(e)(1)(ii)), and COMAR 26.04.14.07C(2) caps what the PRO may pass to members for its MDE registration fee, and CAA says its fee collection dates are not yet set
Jan 1, 2026: Producers must appoint a PRO to address their covered materials (statutory, E2SSB 5284 Sec. 103(1))
May 31, 2026: Interim Producer Report (simplified reporting categories) due to CAA, with the Interim State Addendum signed (CAA-set date, not statutory)
2027 early fees published October 1, 2026 (CAA, eight per-pound rates; invoice timing not published; RCW 70A.208.040(3)(b)); cost-share ramp Feb 15, 2030 to 2032
Deadlines change as rulemaking settles. Confirm current dates in the CAA producer portal or with the state agency before relying on them.
How the sequence works
Every enacted program is built on the same four steps in the same order, though the dates differ, and in Maine registration, reporting, and invoicing cannot start until a Stewardship Organization is under contract. First you determine whether you are the responsible producer for a given item, which is a hierarchy question and not always the obvious answer. Second you register, usually through the Circular Action Alliance producer portal, where one account serves most states but each state needs its own State Addendum. Third you file a supply report describing what you sold into the state by material and weight. Fourth, some time later, an invoice arrives based on that data.
The gap between step three and step four is where producers are caught out. Minnesota requires PRO membership from July 2025, and its first reimbursement floor is February 2029. Maryland reports now and its reimbursement ramp starts July 2028. Reporting obligations are live in states where no fee has ever been charged.
What "simplified reporting categories" means
The phrase appears on this page and across the state timelines because it is CAA's own name for a report type. The 2026 filing for Minnesota, Maryland, and Washington is called the "Interim Producer Report: Simplified Reporting Categories", covering the 2025 data year and due May 31, 2026. Oregon, Colorado, and California filed an Annual Supply Report on the same date instead.
The difference is how much detail the report carries. CAA's Reporting Policy defines the Annual Supply Report as the default type, which "generally includes supplied pounds in the State's reporting categories, a detailed methodology, brands, and other information as required in the State Addendum". The interim report asks for less, because the detailed categories do not exist yet in those three states.
CAA's Maryland producer guidance states that producers "report supply data in simplified reporting categories by May 31, 2026", and that "Detailed material reporting categories have not yet been finalized, and detailed producer reporting will not occur until after the Program Plan is approved". So a producer in Minnesota, Maryland, or Washington is reporting against a set that CAA has not finished defining, and CAA says detailed reporting in Maryland and Minnesota will not occur until after the program plan is approved or complete.
The category list itself is published on the CAA Producer Portal rather than on a public page, so a producer has to be registered to see the fields. The data a pre-program state asks for today is a subset of what it will ask for later, so building only to the interim set means rebuilding. Both sets draw on the same underlying data, which is material, weight, resin code, coatings, post-consumer recycled content, and recyclability evidence by component and by SKU. That is set out in Prepare for U.S. Packaging EPR.
For 2027, CAA has not published a report planning table, so the date rests on its Reporting Policy V2.0, which says that “Participants’ Producer Annual Supply Reports are due by May 31, annually, based on supply in the prior calendar year, unless otherwise communicated by CAA” (section 3.3). Oregon, Colorado, and California producers can therefore expect an Annual Supply Report on CY2026 data by May 31, 2027, although the policy also says that when a program first launches its State Addendum may set unique reporting requirements and deadlines, which could apply to California as its full program starts in 2027. CAA has not announced 2027 report dates for Minnesota, Maryland, or Washington, and Maryland’s June 30 registration filing by the PRO under COMAR 26.04.14.07A(1) is a separate obligation.
Sources: CAA "Covered Materials & Producer Definitions: Maryland", Part 1 Guidance 2026, read 2026-08-23; CAA Reporting Policy V2, June 2026, read 2026-09-02; CAA 2026 EPR Producer Report Planning tables, read 2026-08-26. CAA had not posted a 2027 producer report planning table as of October 25, 2026, the date the Atlas last checked CAA’s Producer Resource Center.
What happens if you miss one
Missing a date does not trigger a penalty on the day it passes. In the CAA-administered states it starts a defined process, which sets how much time a late producer has.
CAA's Producer Delinquency Policy (Version 2.0, April 2026) lists eight triggers: failure to register, report, and pay; a report not submitted by its due date; an invoice not paid by its due date; inaccurate registration; inaccurate reporting; missing documentation; missing retained records; and non-cooperation with a verification audit. Escalation runs in four stages: a Notice of Delinquency, reminder notices at CAA's discretion, a Notice of Unresolved Delinquency once the window expires, and then transmission of the delinquency to the state regulator.
The policy defines the Delinquency Resolution Period as "three months from CAA's determination of the Delinquency, as reflected by the date the Notice of Delinquency is issued to the Producer", unless the initial Notice of Delinquency states otherwise, and if the notice names an earlier determination date, the clock runs from that earlier date instead.
A producer that comes in voluntarily resolves the delinquency inside that window, so it is not escalated to a regulator when the window ends. The escalation is administrative, and the statutory penalties remain available alongside it: Oregon DEQ can assess up to $25,000 per day, California up to $50,000 per day per violation (PRC 42081(a)(1)), accruing only from 30 calendar days after notice of the violation (PRC 42081(a)(3)), with a violation of Section 42050 counted by brand name, package or product line, package or product form, covered material category, and package or product size (PRC 42081(a)(2)), and Maryland $5,000 to $20,000 per violation. The PRO process and the state enforcement power run in parallel.
Oregon is the one state where the consequence is also public. DEQ publishes a quarterly producer status list. Its first, dated April 9, 2026, named 304 producers for failing to register, report, or pay, and its second, dated September 4, 2026, named 198. The listing process runs a 90-day CAA contact window and then a 30-day DEQ cure window before a producer appears on it.
Oregon EPR reporting deadlines
SB 582, Plastic Pollution & Recycling Modernization Act (2021). Administered by Oregon DEQ through Circular Action Alliance (the only approved PRO; producers may form their own under the RMA).
Mar 31, 2025: Producers, except small producers and producers that did not sell, offer for sale, or distribute covered products in or into Oregon in 2024, had to pre-register with a PRO and submit 2024 supply data by this date under OAR 340-090-0870. Missing it did not bar later registration. Failing to register with or become a member of a PRO is a Class I violation (OAR 340-012-0098(1)(a)). Producer action
Mar 31, 2025: CY2024 Annual Supply Report due under DEQ rule OAR 340-090-0870 (no statute sets the date); this is the report the 2026 fee invoices are calculated from Producer action
Jul 2025: Program launched Jul 1, 2025; CAA issued the first fee invoices starting in June 2025 Producer action
Feb 2, 2026: HB 4030 introduced, proposing exemptions for certain berry and meat, poultry, fish, and seafood packaging; it died in the House Rules Committee when the 2026 session adjourned (Mar 6, 2026)
Feb 6, 2026: Federal court injunction (NAW members only)
Mar 5, 2026: DEQ warning letters to non-compliant producers (date as reported by Resource Recycling, Apr 21, 2026; DEQ's Apr 9, 2026 Producer Status List confirms listed producers were first sent a DEQ Warning Letter with a 30-day correction window)
May 4, 2026: Oregon DEQ approves the CAA program plan amendment on verification of responsible end markets, effective immediately
May 31, 2026: 2025 Annual Supply Report due (a date CAA set; no statute sets it) Producer action
Jun 25, 2026: Lollicup USA (Karat) filed second suit; class action for non-NAW producers
Jul 1, 2026: The opportunity-to-recycle definition expands to the residential and commercial tenants of landlords or property managers that are collection-service customers for their tenants' benefit, with DEQ exemptions for extreme compliance barriers; a local government duty rather than a producer one (ORS 459A.005(3) as amended by 2015 Or. Laws ch. 534 sec. 2, operative date set by sec. 3 as amended by SB 582 Sec. 50)
Jul 13-17, 2026: NAW trial on the merits held (five-day bench trial, DCC + Due Process claims)
Jul 16, 2026: Stipulation filed by the parties (ECF 9, Exhibit 1; terms as summarized by Arnold and Porter, July 22, 2026): DEQ agreed to pause pre-enforcement notices against putative class members (non-NAW producers) through at least Aug 31, 2026
Aug 27, 2026: NAW v. Feldon decided: RMA upheld on both claims (ECF 205); final judgment for the Director Aug 28 (ECF 206)
Aug 31, 2026: DEQ pre-enforcement pause was set to end on this date unless extended. Docket accessed Sep 16, 2026: no extension, amended stipulation, or dismissal filed. The parties could extend by written agreement without docketing it, so the public record cannot say which happened. Do not treat the pause as in force
Sep 24, 2026: NAW files a notice of appeal to the Ninth Circuit from the Aug 28 judgment (ECF 209)
Sep 30, 2026: NAW v. Feldon: the Ninth Circuit dockets the appeal as No. 26-6404; NAW opening brief due Dec 17, 2026 and Oregon answering brief Jan 18, 2027 (CourtListener, accessed Oct 4, 2026)
Oct 1, 2026: CAA published the 2027 Oregon Producer Fees Schedule. Final rates fall a median 48 percent, mostly because CAA is returning about $80 million of program reserves, plus $3 million of SIM fees, through 2027 rates; before that drawdown, base rates fell a median 7 percent and 22 of 62 rose. Two rows are new, as the approved program plan set out: PE and PP caps and lids and HDPE package handles (41 cents per pound) and molded pulp food serviceware (43 cents per pound). Other small-format plastic moves off the PRO list at 78 cents per pound
Sep 2026: DEQ has posted the public comments on the CAA 2025 Oregon annual report (20 pages, including a City of Portland letter of Sep 9) beside the report; the page gives no posting date, the comments file’s server date is Sep 23, 2026, and no DEQ decision on the report is posted (DEQ RMA page)
Oct 16, 2026: Joint status report due in Lollicup, not later than this date (ECF 12, order of Sep 10, 2026 granting the ECF 11 joint motion)
Oct 19, 2026: Comment closes, 5:00 p.m. PT, on CAA's third program plan amendment (covered material categories), to RethinkRecycling@deq.oregon.gov Producer action
Oct 20, 2026: DEQ public hearing 1, 10 a.m., on the third RMA rulemaking (new exempt product classes, glass obligations) Producer action
Oct 21, 2026: DEQ public hearing 2, 6 p.m., on the third RMA rulemaking Producer action
Oct 30, 2026: Comment closes, 4 p.m., on DEQ's third RMA rulemaking, to RMARulemaking3@deq.oregon.gov Producer action
Dec 15, 2026: DEQ final report and recommendations for legislation on the compostability of covered products and their effects on composting systems due to the legislative interim committees on the environment (SB 582 Sec. 44a(3))
Dec 31, 2026: Mandatory life cycle evaluation reports due to DEQ from the large producers on both the preliminary and final top 25 lists, on DEQ templates; an ISO 14040 and 14044 study with third-party critical review takes longer than the date suggests Producer action
Jan 2027: 2027 fees invoiced, 50% in January and 50% in July 2027 (CAA 2027 Oregon Producer Fees Schedule, Oct 1, 2026) Producer action
May 31, 2027: 2026 Annual Supply Report expected, CY2026 data (CAA Reporting Policy V2.0 s.3.3 default date, unless CAA communicates otherwise; no 2027 table published yet) Producer action
Jun 30, 2027: Mandatory life cycle evaluation reports due to DEQ from the five large producers added only on the final top 25 list (marked + on DEQ's list), six months after the Dec 31, 2026 date Producer action
HB 22-1355, Producer Responsibility Program for Statewide Recycling (2022). Administered by Colorado CDPHE through Circular Action Alliance (packaging and paper); Interchange 360 (LPMA) runs a separate CDPHE-approved individual program for packaging of lubricants, antifreeze, and other petroleum-based fluids used in transportation and mechanical applications.
Jul 31, 2025: CY2024 Annual Supply Report (2024 supply data) due to CAA; producers had to register with CAA by Oct 1, 2024 and participate from Jul 1, 2025 Producer action
Dec 2025: CDPHE approved Colorado program plan
Jan 2026: First mandatory fee payments due Producer action
Mar 11, 2026: Interchange 360 (Lubricants Packaging Management Association) starts its CDPHE-approved individual program for packaging of lubricants, antifreeze, and other petroleum-based fluids used in transportation and mechanical applications such as motor oil and antifreeze, with diesel exhaust fluid and aerosol lubricants on its Applicable Products List; CDPHE approved the plan on September 9, 2025 and says a producer may need to register and report with both CAA and Interchange 360 (Interchange 360 Colorado producer page; CDPHE Producer Responsibility Program page, accessed October 11, 2026)
May 31, 2026: 2025 Annual Supply Report due (CAA-set date, not statutory) Producer action
Oct 1, 2026: CAA published the 2027 Colorado Producer Dues Schedule, due by this date under 6 CCR 1007-2 Part 1 Sec. 18.9.2. Dues rise a median 14 percent, and 19 percent on Minimum Recyclable List materials, and are invoiced 50% in January and 50% in July 2027. The schedule says detailed eco-modulation guidance with the CDPHE bonus benchmarks would be posted by Oct 1, and Interchange 360 said it would release its 2027 eco-modulation guidance on Oct 1 (Interchange 360, Sep 23, 2026); CAA’s Colorado guidance page now lists its eco-modulation guidance with the CDPHE bonus benchmarks as revised October 2026, in its login-only Producer Portal, and Interchange 360 posted its Colorado Producer Eco-Modulation Guidance, which its page lists as last updated October 1, 2026 (CAA page accessed October 4, 2026; Interchange 360 page accessed October 7, 2026)
Oct 14, 2026: Interchange 360 producer webinar on its Colorado eco-modulation guidance, 1:00 p.m. ET; its 5 percent PCR bonus applies from January 1, 2027 (Interchange 360 webinar page; Interchange 360 Colorado Producer Eco-Modulation Guidance, October 2026)
Oct 21, 2026: Scheduling conference held in NAW v. Ryan; oral argument on the Auto Care Association's motion to intervene set for November 6, 2026 (ECF 25)
Oct 28, 2026: Producer Responsibility Advisory Board meets, 1:30 to 4:30 p.m.
Nov 6, 2026: Oral argument on the Auto Care Association's motion to intervene in NAW v. Ryan, 9:30 a.m. (ECF 25)
Nov 18, 2026: Producer Responsibility Advisory Board meets, 12:30 to 2:30 p.m.
Jan 2027: 2027 dues invoiced, 50% in January and 50% in July 2027, based on CY2025 supply data (CAA 2027 Colorado Producer Dues Schedule, Oct 1, 2026; CAA Producer Report Planning table) Producer action
May 31, 2027: 2026 Annual Supply Report expected, CY2026 data (CAA Reporting Policy V2.0 s.3.3 default date, unless CAA communicates otherwise; no 2027 table published yet) Producer action
Jan 31, 2028: Interchange 360 reviews Local End Use bonus claims on 2027 data; the bonus is 1 percent of dues per qualifying material (Interchange 360 Colorado Producer Eco-Modulation Guidance, October 2026) Producer action
SB 54, Plastic Pollution Prevention & Packaging Producer Responsibility Act (2022). Administered by CalRecycle through Circular Action Alliance.
Mar 7, 2025: Gov. Newsom directs CalRecycle to restart SB 54 rulemaking
Mar 9, 2026: AB 2253 (recycled content claims) referred to committee
Late May 2026: AB 2253 passed Assembly 42-19; ordered to Senate
Jul 1, 2026: AB 2253 cleared Senate Environmental Quality 4-2; re-referred to Senate Appropriations
Jul 2, 2026: AB 2253 amended: the credit-based mass balance prohibition is struck from the bill
Aug 3, 2026: AB 2253 placed on the Senate Appropriations suspense file 7-0
Aug 13, 2026: AB 2253 out of Senate Appropriations 5-2, do pass as amended; amendment expressly permits proportional attribution (ISO 22095-2:2026); applies to all products from Jan 1, 2030
Aug 21, 2026: AB 2253 amended again in the Senate; this is the version the Assembly concurred in
Aug 28, 2026: AB 2253 passes the Senate 27-10
Aug 30, 2026: Assembly concurs in Senate amendments 42-20; to enrollment
Sep 10, 2026: AB 2253 enrolled Sep 3 and presented to the Governor; he has until Sep 30, 2026, after which an unreturned bill becomes a statute (Cal. Const. art. IV, sec. 10(b)(2))
Sep 27, 2026: Governor vetoes AB 2253 (Office of the Governor, legislative update, Sep 27, 2026)
Mar 17, 2026: SB 343 constitutional challenge filed by a coalition of trade associations and California commodity commissions (Case 3:26-cv-01675)
Jun 2, 2026: Oceana, NRDC, and Californians Against Waste sued CalRecycle over SB 54 regs (S.F. Superior Court)
Jun 22, 2026: 17-state AG coalition + NAW filed federal challenge to SB 54 (E.D. Cal.)
May 31, 2026: Three producer filings due to CAA: 2026 Baseline Producer Report (CY2023 data), Annual Supply Report (CY2025), Annual Source Reduction Report (CY2025). CAA's report-planning dates; the baseline supply data is due with the PRO application within 30 days after May 1 under 14 CCR 18980.5(b), (d), and CAA's May 2026 California guidance treats that deadline as June 1, 2026 because May 31 was a Sunday Producer action
Jun 1, 2026: Producer registration deadline (PEPRS/CAA) Producer action
Jun 15, 2026: CAA filed its draft 5-year program plan with the Producer Responsibility Advisory Board; 60-day public comment period opens (closes ~Aug 14, 2026)
Aug 3, 2026: Individual Source Reduction Plans due to CAA Producer action
Aug 14, 2026: Public comment period on the draft program plan closes Producer action
Aug 17, 2026: CAA scheduled 2026 Early Fee invoices for the week of Aug 17, calculated from 2025 supply data, payment due within 45 days of the invoice date (CAA producer bulletin, Aug 2026), as one installment (CAA 2026 Producer Report Planning table). The CAA newsletter of September 29, 2026 confirms the invoices were issued; CAA has not published the issue date Producer action
Oct 1, 2026: CAA published the preliminary 2027 California Producer Fees Schedule: a base fee for each covered material category plus, on plastic components, 3 cents per pound for reuse investment, 26 cents per pound for the PPMF, and 0.1 cent per component. The rates are non-binding until CalRecycle approves the program plan. Invoices go out 50% in January and 50% in July 2027, with the full-year PPMF portion billed in January
Oct 1, 2026: 2026 Early Fee payment due on or about this date through Oct 5, within 45 days of the invoice date; CAA scheduled the invoices for the week of Aug 17, 2026 (CAA bulletin, Aug 2026), and the due date on your invoice controls Producer action
Oct 13, 2026: CAA submitted its final draft program plan to CalRecycle, for approval by Jan 1, 2027 (CAA release, Oct 13, 2026; CalRecycle Source Reduction Reporting Guidance, Aug 4, 2026)
Oct 14, 2026: Rule 26(f) meet and confer deadline in CLFP v. Bonta, the SB 343 labeling case, set by the September 23 order (ECF 33) as stated in the plaintiffs’ October 8 motion (ECF 35)
Oct 16, 2026: SB 54 Advisory Board meeting, 10 a.m. to 4 p.m., CalEPA headquarters (CalRecycle advisory board page)
Oct 22, 2026: CAA Tribal listening session on its draft rural operational plan for rural, Tribal, and underserved communities (CAA newsletter, Sep 29, 2026)
Oct 23, 2026: Defendants' opposition to the preliminary injunction motion and response to the amended complaint due in Nebraska v. Heller (ECF 51); Director Heller moved to dismiss that day (ECF 60)
Oct 24, 2026: CAA comment closes on the draft California Funding and Services Agreement and project schedules
Oct 26, 2026: Joint discovery plan and confidential early neutral evaluation statements due in CLFP v. Bonta (ECF 33, as stated in ECF 35); an October 23 order on a motion to continue (ECF 37) may have moved this date, and its text is not on the free docket
Oct 28, 2026: Initial disclosures due in CLFP v. Bonta (ECF 33, as stated in ECF 35); an October 23 order on a motion to continue (ECF 37) may have moved this date, and its text is not on the free docket
Nov 4, 2026: Early neutral evaluation conference and case management conference in CLFP v. Bonta, 1:30 p.m., set by the September 23 order (ECF 33) as stated in the plaintiffs’ October 8 motion (ECF 35); an October 23 order on a motion to continue (ECF 37) may have moved this date, and its text is not on the free docket
Nov 6, 2026: SB 54 Advisory Board meeting, 10 a.m. to 4 p.m., CalEPA headquarters (CalRecycle SB 54 page)
Nov 9, 2026: Hearing date the plaintiffs noticed for their motion to add SB 54 claims in CLFP v. Bonta (ECF 35), with no oral argument unless the court requests it
Nov 13, 2026: Comment closes on CAA's producer responsibility plan at CalRecycle; email packaging@calrecycle.ca.gov with the subject line PRO Plan Comments (CalRecycle SB 54 page) Producer action
Jan 1, 2027: Watch for binding 2027 California rates: CAA says its preliminary rates are non-binding until CalRecycle approves the program plan, due on or before this date
Jan 1, 2027: Target date for CalRecycle approval of CAA's program plan and program start (CAA milestone list; CalRecycle source reduction guidance); CalRecycle must act on the revised plan within 75 calendar days of receiving it (14 CCR 18980.6.1(b)(2))
Mar 1, 2027: CalRecycle transmits the liable-person list and surcharge amounts to CDTFA; the $500M mitigation surcharge is due 30 days from CDTFA's assessment (PRC 42064(b), (c)(1), (e)(1)) Producer action
May 31, 2027: 2026 Annual Supply Report expected, CY2026 data (CAA Reporting Policy V2.0 s.3.3 default date, unless CAA communicates otherwise or sets different launch-year requirements in the California State Addendum; no 2027 table published yet) Producer action
Jun 30, 2027: First California circular economy administrative fee due from CAA to CalRecycle, by the end of the 2026-27 fiscal year and every three months after (PRC 42053.5(a)(1))
LD 1541 (2021) / LD 1423 (signed Jun 2025). Administered by Maine DEP, with no Stewardship Organization (SO) in place. RFP-202605094 closed Aug 18, 2026 with zero proposals; CAA declined to bid; DEP said Sep 11, 2026 it will revise and reissue the RFP, with no date given.
Jun 15, 2026: DEP issued SO selection RFP-202605094
Aug 18, 2026: RFP closed with zero proposals; CAA says it decided not to bid
Aug 20, 2026: DEP announced no bids and is assessing all options
Sep 11, 2026: DEP announces it will revise the SO RFP. Program sits at step four of nine, Contracting an SO, and the schedule is being reassessed. No reissue date and no open solicitation
May 31 (annual): Producer reporting, on DEP's fixed annual calendar Producer action
Jul 1 (annual): Producer invoicing
Sep 1 (annual): Producer payment Producer action
Oct 1 (annual): Municipal reimbursement
TBD: Startup fees would be due within 180 days of an SO contract, and only from producers other than low-volume producers (Ch. 428); no SO exists after the Aug 18, 2026 RFP drew no bids Producer action
TBD: Full program operational if an SO is designated on the revised schedule
HF 3911, Packaging Waste and Cost Reduction Act (2024). Administered by Minnesota MPCA through Circular Action Alliance.
Jul 1, 2026: PRO must register with the MPCA commissioner (115A.1443 Subd. 1(a)); producers had to appoint a PRO by Jan 1, 2025
May 26, 2026: MPCA Request for Comments on possible EPR rules published in the State Register (Revisor ID R-04992); comments closed Jul 24, 2026
May 31, 2026: Interim Producer Report (simplified reporting categories) due (CAA-set date, not statutory) Producer action
Sep 14, 2026: MPCA opens 60-day comment on the draft 2026 Needs Assessment, covering baseline rates, investment, service provider reimbursement methodology, sustainable design, and outreach
Nov 13, 2026: Comment closes on the MPCA draft 2026 Needs Assessment Producer action
Dec 8, 2026: Producers registered with CAA add their brand information in the Brand Management tab of CAA's Producer Portal; CAA says it will leave any producer that has not done so by this date out of its next list of registered producers and brands to the regulator (CAA-set date) Producer action
Dec 31, 2026: MPCA needs assessment complete
2027: 2027 producer report date not announced: CAA's Producer Resource Center lists 2026 reports only (checked Oct 25, 2026)
Oct 1, 2028: PRO submits stewardship plan to the MPCA commissioner (115A.1451 subd. 1), after sending the draft to the advisory board at least 60 days earlier (subd. 2)
Jan 1, 2029: Producer PRO agreements required; prohibition on sale without agreement Producer action
Feb 1, 2029: 50% reimbursement floor for service providers (115A.1455 subd. 4); the PRO may charge member fees earlier (115A.1443 subd. 3(c))
Feb 1, 2030: 75% reimbursement floor for service providers (115A.1455 subd. 4)
Feb 1, 2031: 90% reimbursement floor for service providers, and each year thereafter (115A.1455 subd. 4)
SB 901 (Ch. 431 of 2025), Environment, Packaging and Paper Products, Producer Responsibility Plans; Md. Envir. Title 9, Subtitle 25. Administered by Maryland MDE through Circular Action Alliance (single approved PRO; additional PROs possible only from Jul 1, 2033).
May 25, 2026: First implementing regulations effective
May 31, 2026: Producer registration with CAA and simplified reporting to CAA due (CAA-set date); COMAR 26.04.14 fixes no May 31 date Producer action
Jul 1, 2026: PRO files its MDE registration listing participating producers, brands, and covered materials by weight, and pays the annual registration fee (COMAR 26.04.14.07A(1)(a)). An IPP-route producer files its own registration and fee with MDE on this date (.07A(1)(b)); a PRO member reports to its PRO instead, on the PRO-set date (.07A(2))
Oct 8, 2026: Packaging and Paper Products Advisory Council meeting, 9 to 11 a.m. ET, open to the public with time for comment (CAA September 2026 newsletter; MDE does not post the date)
2027: 2027 producer report date not announced: CAA's Producer Resource Center lists 2026 reports only (checked Oct 25, 2026)
Jun 30, 2027: Recurring annual registration deadline. COMAR 26.04.14.07A(1) sets it as beginning July 1, 2026 and each year thereafter, by no later than June 30 Producer action
Jul 1, 2027: MDE must develop a statewide list of covered materials determined to be recyclable or compostable through curbside recycling programs (Md. Envir. 9-2508(a)(1)). The statute sets no publication date
Jul 1, 2028: Producer responsibility plans due: each producer, individually or through a PRO, submits a plan to MDE on or before July 1, 2028 and every 5 years after (Md. Envir. 9-2505(b)(1)). For producers not joining a PRO, COMAR 26.04.14.10C sets the IPP date as July 1, 2028 or a later date the Department identifies. Also the first reimbursement floor: at least 50% of the cost per ton (Md. Envir. 9-2505(e)(1)(ii)) Producer action
Oct 29, 2028: No producer may sell, offer for sale, distribute, or import covered materials for use in Maryland without a Department-approved responsibility plan on file. The regulation sets this date or a later date identified by the Department, so it can move (COMAR 26.04.14.10B) Producer action
Jul 1, 2029: Reimbursement floor rises to at least 75% of the cost per ton (Md. Envir. 9-2505(e)(1)(ii))
Jul 1, 2030: Reimbursement floor rises to at least 90% of the cost per ton (Md. Envir. 9-2505(e)(1)(ii))
E2SSB 5284, Recycling Reform Act (2025). Administered by Washington Ecology through Circular Action Alliance.
Jan 1, 2026: Producers must appoint a PRO to address their covered materials (statutory, E2SSB 5284 Sec. 103(1)) Producer action
Mar 1, 2026: A PRO registers with Ecology on behalf of its producers, and annually after (statutory, E2SSB 5284 Sec. 103(2))
May 31, 2026: Interim Producer Report (simplified reporting categories) due to CAA, with the Interim State Addendum signed (CAA-set date, not statutory) Producer action
Jul 1, 2026: Producers must be members of a registered PRO, or register as a PRO implementing an individual plan (statutory, E2SSB 5284 Sec. 104(1)(a)) Producer action
Aug 5, 2026: Ecology opens comment on the preliminary statewide collection lists it is developing; comment closed Aug 19, 2026
Aug 19, 2026: Comment closed at 11:59 p.m. PT on Washington Ecology's preliminary statewide collection lists, which determine what counts as collected statewide Producer action
Sep 1, 2026: CAA (as PRO) one-time payment to Ecology due, covering Ecology costs from Jul 27, 2025 through Jun 30, 2027, in an amount Ecology determines. An individual producer registered as its own PRO makes a separate one-time payment covering only the incremental costs of its registration. Statutory: RCW 70A.208.040(3)(a)(ii)
Sep 2, 2026: Comment closed on Ecology's draft rule language for chapter 173-950 WAC, a separate track from the collection lists Producer action
Oct 1, 2026: CAA publishes the 2027 Washington Early Fees Schedule: eight per-pound rates by material category, from $0.002 to $0.030, with no invoice date or supply-data year (CAA schedule, Oct 1, 2026)
Oct 1, 2026: Ecology opens public comment on the draft preliminary needs assessment, through Oct 30, 2026 (Ecology needs assessments page, accessed October 4, 2026); the final preliminary assessment is due Dec 31, 2026 (E2SSB 5284 Sec. 111)
Oct 1, 2026: Ecology was required to develop initial statewide collection lists for use in the needs assessment by this date (RCW 70A.208.090). Ecology took public comment on preliminary lists Aug 5 to 19, 2026; the statute requires final lists to be published no later than 30 days after Ecology approves a plan
Oct 8, 2026: Recycling Reform Act Advisory Council meeting, 10 a.m. to 2 p.m. PT, hybrid, in person at the WM Spokane SMaRT Center (RRA Advisory Council site)
Oct 30, 2026: Comment closes on Ecology's draft preliminary needs assessment, open since October 1. Comment through Ecology's portal Producer action
Nov 19, 2026: Recycling Reform Act Advisory Council meeting, 9 to 11:30 a.m. PT, virtual (RRA Advisory Council site)
Dec 31, 2026: Final preliminary needs assessment
Mar 31, 2027: Ecology determines the PRO annual registration fee, and every Mar 31 thereafter. Statutory: RCW 70A.208.060(4)(a)
May 1, 2027: PRO begins paying Ecology the annual registration fee. Statutory: RCW 70A.208.040(3)(a)(iii)
2027: 2027 producer report date not announced: CAA's Producer Resource Center lists 2026 reports only (checked Oct 25, 2026)
Sep 2027: Draft full needs assessment out for public comment
Dec 31, 2027: Final full needs assessment
Oct 1, 2028: PRO submits program plan
Mar 1, 2029: Ecology begins enforcement against noncompliant producers that are not PRO members, and a producer that is not a member in good standing of a registered PRO and has not submitted an individual plan may not introduce covered materials (E2SSB 5284 Sec. 104(2), Sec. 106(2)(m)) Producer action
Feb 15, 2030: 50% reimbursement floor: the PRO must reimburse service providers at least 50% of net costs (E2SSB 5284 Sec. 117(2)(a)(i)); not a producer fee start date
It depends on the state, but most enacted programs use a spring report to CAA. In 2026, Annual Supply Reports were due May 31 in Oregon, Colorado, and California, and Interim Producer Reports (simplified reporting categories) in Minnesota, Maryland, and Washington. Registration deadlines run separately and generally come earlier.
Do I have to report in a state that is not charging fees yet?
Usually yes. Registration and supply reporting obligations begin before fees in several states. Minnesota has required producers to be members of a PRO since July 1, 2025, and its first reimbursement floor is February 1, 2029, but the PRO may charge member fees before then. Maryland is in a similar position, and Washington's first early fees are for program year 2027. Treat reporting and paying as separate schedules.
Do I register separately in every state?
Generally no. The Circular Action Alliance is the producer responsibility organization in every enacted state except Maine, which uses a Stewardship Organization not yet selected, so a producer keeps one CAA account but signs a State Addendum and files the required reports for each CAA state. State-specific rules and exemptions still apply on top.
What happens if I miss an EPR deadline?
Penalties vary widely. California allows up to $50,000 per day per violation and does not start the clock until 30 calendar days after notice (PRC 42081(a)(1) and (a)(3)), Oregon up to $25,000 per day, Maryland $5,000 to $20,000 per violation, and Colorado sets an administrative penalty of up to $5,000 for the first day plus up to $1,500 per day, rising to up to $20,000 plus $6,000 per day for a third violation within 12 months (C.R.S. 25-17-710(1), each tier "not to exceed"), plus a sales prohibition. Oregon DEQ also publishes a quarterly public list of noncompliant producers.
Explore each state in depth
Every state guide has the fee schedule where one has been published, registration deadlines, program plan status, eco-modulation detail, the statute and any implementing rule, and exemptions.