Every US packaging EPR deadline through 2027

Seven states, four programmes already collecting or about to, and a set of dates that do not line up with each other. Here they all are.

Last reviewed 27 July 2026 · Packfile is not a law firm and this is not legal advice

The awkward thing about US packaging EPR is that it is seven separate programmes on seven separate clocks. Below is every date we track, in order. Where a date has passed, it is still worth reading — a missed registration is a live exposure, not a closed one.

1 Jul 2025Oregon — fees begin. First US state to charge.
1 Jan 2026Colorado — fees begin.
9 Apr 2026Oregon — DEQ publishes its first quarterly producer status list, naming roughly 250 non-compliant producers. What to do if you are on it.
31 May 2026Six states — annual supply reports for 2025 data due to CAA. This is the submission that sets 2027 fees.
1 Jun 2026California — producer registration, or small producer exemption application via PEPRS.
1 Jul 2026Washington — producers required to join CAA. California — baseline producer report using 2023 data. Maryland — CAA plan filing to MDE.
1 Aug 2026California — individual source reduction plans.
3 Aug 2026Maine — stewardship organisation selection milestone.
Q3 2026Maine — first reporting expected. Oregon — next quarterly producer status list.
31 Dec 2026Oregon — life-cycle impact evaluation disclosure due for the 25 largest producers by weight.
1 Jan 2027California — fees begin, calculated from data reported during 2026. First 10% plastic source reduction milestone. Why this year's accuracy sets that invoice.
Q2 2027All reporting states — annual supply reports for 2026 data. The main cycle of the year.
2028Maryland — fees begin.
2029–2030Minnesota and Washington — fee phase-in.

The one date that is not on the list

Registration. It has no deadline in the useful sense, because it is already overdue everywhere and it stays open. Registering with Circular Action Alliance is free, covers all seven states in one action, and is the specific failure Oregon’s public list records. If you are behind on everything, do that first — being registered with incomplete data is a far better position than being unregistered with perfect data.

Where the deadlines are heading

Seven states have enacted programmes. More are in the legislature each session, and the pattern is now well established enough that new states largely copy the CAA producer responsibility organisation model rather than inventing one. A brand that builds a defensible packaging dataset once answers each new state by re-cutting the same table — which is the argument for doing the data properly rather than assembling it under deadline pressure a state at a time.

Which of these apply to you? The free exposure check runs the threshold test for all seven states against your revenue and category, and tells you which dates are yours.

Run the free check

More on this

Am I an obligated producer?Seven US states now run packaging EPR programmes, and each applies its own test. Here is how to work out your own answer, state by state, without hiring anyone.The small producer exemption, state by stateEvery state exempts small producers. No two states define small the same way, and in California you have to apply for it.Oregon's producer status listIn April 2026 Oregon DEQ published the first quarterly list naming producers that had not complied with the Recycling Modernization Act. It named 250 companies.California's 2027 fee is calculated from your 2026 dataSB 54 fees start in January 2027. What you report during 2026 is the input. That makes this year's accuracy a pricing decision, not a paperwork one.Getting packaging data out of your suppliersThe reason first EPR submissions take one to six months is not the law. It is waiting on people who do not work for you. Here is how to shorten it.