Maryland's SB 901 (Ch. 431 of 2025) runs through a single approved PRO, the Circular Action Alliance (Md. Envir. 9-2502(a)); additional PROs may be designated only on or after July 1, 2033 (9-2505).
Last updated October 25, 2026.
First implementing regulations took effect May 25, 2026. Maryland's program sets a reimbursement ramp: service providers must be reimbursed at rates of at least 50% of the cost per ton on or before July 1, 2028, at least 75% on or before July 1, 2029, and at least 90% on or before July 1, 2030 (Md. Envir. 9-2505(e)(1)(ii)). The July 1, 2026 date is the CAA registration filing with MDE (the producer, brand, and material list), and a producer seeking approval through an Individual Producer Responsibility Plan instead files its own registration with MDE (COMAR 26.04.14.07A(1)).
Maryland's producer registration and Interim Producer Report (simplified reporting categories) deadline was May 31, 2026, a program date CAA set, and COMAR 26.04.14 fixes no May 31 date.
No program fee schedule has been published for Maryland yet, so this section shows no program fee rates. The fee calculator shows a projection for Maryland, estimated from Oregon’s 2026 rates and labeled as an estimate.
Source: SB 901 (2025) + first MDE regulations effective May 25, 2026. Eco-modulation required by statute; factor schedule not yet established.
Multiplier floor: Not established, set in the PRO fee structure under Md. Envir. 9-2505(e)(3)(ii)
Plan submitted: No producer responsibility plan has been filed publicly yet.
Agency approved: Not applicable yet.
Where it stands: Regulations are final. COMAR 26.04.14 was proposed February 6, 2026 (53:3 Md. R. 129), adopted May 5, 2026 (notice of final action published May 15, 2026, 53:10 Md. R. 455) and took effect May 25, 2026. MDE has posted a compliance guide and an exempt producer determination form.
Next milestone: The statutory deadline for the producer responsibility plan filing is July 1, 2028 (Md. Envir. 9-2505(b)(1)). The MDE Packaging and Paper Products Advisory Council met on September 10, 2026 (Meeting 30), and CAA's September 29, 2026 newsletter listed the next meeting for October 8, 2026; MDE's program page posted no date for it, and MDE announces meetings through its email list.
Source: Maryland Department of the Environment; COMAR 26.04.14 (effective May 25, 2026). Agency program page →
The following categories may be fully or partially exempt from producer obligations in Maryland. Verify applicability with the CAA producer portal or Maryland MDE before excluding any materials from supply reports.
Obligation follows a statutory cascade and the shape differs by state. Washington, Maryland, Minnesota, and Maine run five tiers for items sold at a physical retail location: the manufacturer for goods under its own brand or in packaging lacking brand identification; the licensee that manufactures and sells under a brand owned by another party; the brand owner; the U.S. importer where none of those exists in the United States; then the person that first distributes the item in or into the state (RCW 70A.208.020(29)(a)(i); Md. Envir. 9-2501(p)(1)(i) and COMAR 26.04.14.02B(25)(b); Minn. Stat. 115A.1441 subd. 26(a)(1); 38 MRSA 2146(1)(O)(1)). The Oregon and Colorado statutes run three tiers: own-brand or unbranded manufacturer, licensee, then the importer into the United States (ORS 459A.866(1)(a); C.R.S. 25-17-703(30)(a)); in Oregon there is no brand-owner tier. The Colorado rule then sets the order of obligation in four steps (6 CCR 1007-2 Part 1, s18.2.2(A)): the brand owner directing or performing the manufacturing of the packaging, then the brand or trademark licensee directing it, then the manufacturer where no brand is identified, then the importer. California reaches a manufacturer in the state that owns or is the licensee of the brand at tier 1, then the brand owner or exclusive licensee in the state, then whoever sells or distributes in or into the state, with no importer tier (PRC 42041(w); 14 CCR 18980.1.1(a)). Store-brand and private-label goods usually land on the retailer whose brand appears, but the test differs in three states. Colorado's rule reaches the brand owner first only where it directs or performs the manufacturing of the packaging (6 CCR 1007-2 Part 1, s18.2.2(A)(1)). In Oregon the retailer is reached only where it directs the manufacturing, including setting packaging specifications, and ordering finished goods for resale in the normal course of business is not directing manufacturing (OAR 340-090-0860(1)(a)). In California an in-state manufacturer that owns the brand or is licensed to manufacture the goods is the producer ahead of the brand owner (14 CCR 18980.1.1(c)(1)). Washington, Maryland, Minnesota, and Maine make the franchisor the producer where it has franchisees with a commercial presence in the state, and Colorado's rule does so where it has franchisees that operate in Colorado (RCW 70A.208.020(29)(a)(vi)(B); COMAR 26.04.14.02B(25)(g); Minn. Stat. 115A.1441 subd. 26(a)(6)(ii); 38 MRSA 2146(1)(O); 6 CCR 1007-2 Part 1 s18.2.2).
MD: Standard hierarchy; MDE's COMAR 26.04.14 compliance guide with FAQs is now marked Rev 2, October 2026. General framework; verify the statutory definition and your specific role before registering.
These attributes are the fee inputs, so they are best captured at design time. CAA collects these attributes through one Producer Portal account, with a separate Producer Report for each state where the producer has signed a State Addendum, and state-specific rules still apply. Retain supporting records for at least 5 years, the minimum COMAR 26.04.14.09B sets, to substantiate reports, exemptions, and credits.
MDE to develop the statewide list of covered materials recyclable or compostable through curbside programs by July 1, 2027 (Md. Envir. 9-2508(a)(1)); no publication date is set. Covered materials / recyclability list →
The producer responsibility plan, due July 1, 2028, must set goals for each covered material type that include the percentage of postconsumer recycled content covered materials must contain (Md. Envir. 9-2505(c)(1)(iii)), and fees must be higher for low recycled content and discounted for high recycled content (9-2505(e)(3)(ii)). No percentage is set yet.
The same plan goals include the percentage of covered materials to be waste reduced (9-2505(c)(1)(iii)); none is set yet, and lighter packaging will lower future tonnage-based fees.
Maryland applies the Toxics-in-Packaging heavy-metals limit (100 ppm total of the four metals); verify any PFAS food-packaging restrictions.
Sources: Maryland Toxics in Packaging; Toxics in Packaging Clearinghouse member list (Maryland is a member). The EPR fee calculator models the dollar impact of a design change, and this section does not estimate fees.
Statute: SB 901 (Ch. 431 of 2025), Environment, Packaging and Paper Products, Producer Responsibility Plans, codified at Md. Envir. Title 9, Subtitle 25. Read the statute →
Implementing rule: COMAR 26.04.14. Notice of final action published May 15, 2026 (Md. Reg. 53:10); effective May 25, 2026. Read the rule →
Primary sources. Where the statute and an agency summary disagree, the statute and the adopted rule control.
The EPR Atlas hub includes interactive tools to model your Maryland EPR cost exposure and compare it across all seven enacted states.