Packfile  ·  US packaging EPR data, filings and fee control

Cascade Provisions Co.
US Packaging EPR Exposure Assessment

Prepared 27 July 2026  ·  Seven enacted state programmes  ·  Scope: all packaging and paper placed on the US market, FY2025 volumes

Estimated fees, states already charging
$4,360
Per year, at current published rates
Run-rate once all seven are live
$30,259
By 2029–2030 on today’s volumes
Obligated states, participation unconfirmed
6
Registering with the PRO costs nothing — the exposure is in not being listed
Packaging weight on estimated data
74%
Needs supplier confirmation before filing
Read the two fee numbers correctly. Only Oregon and Colorado are charging today, and together they are about 3% of the US population — which is why the live number is small. California alone is roughly 11.5% of the US, and its fees begin in January 2027. Critically, the 2027 California invoice is calculated from the packaging data you report in 2026, so the accuracy of this year’s submission is what sets next year’s bill. A widely quoted industry rule of thumb puts PRO fees at 0.5–1% of sales; computed from the published per-material rates and the seven states actually enacted, your figure is nearer 0.11% of revenue. We would rather show you the arithmetic than the rule of thumb.

Where you stand, state by state

Each state applies its own small-producer test. The tests are not the same, and being exempt in one state says nothing about the others.

StateStatusTonnes Est. annual feeDates that matter
California
SB 54 (Plastic Pollution Prevention and Packaging Producer Responsibility Act)
⚠ Obligated — participation unconfirmed
Participation in this state's programme is not confirmed. CAA takes a single registration covering all states, but each state programme still has to list you as a participating producer — registering once does not automatically cover a state you added later.
47.98$16,7992026-06-01 — Producer registration / small-producer exemption application deadline (passed).
2026-07-01 — Baseline producer report using 2023 data due.
2026-08-01 — Individual source reduction plans due.
Washington
E2SSB 5284 (Recycling Reform Act)
⚠ Obligated — participation unconfirmed
Participation in this state's programme is not confirmed. CAA takes a single registration covering all states, but each state programme still has to list you as a participating producer — registering once does not automatically cover a state you added later.
9.62$3,3692026-07-01 — Producers must join CAA (passed).
2029-2030 — Fee obligations begin.
Maryland
SB 901
⚠ Obligated — participation unconfirmed
Participation in this state's programme is not confirmed. CAA takes a single registration covering all states, but each state programme still has to list you as a participating producer — registering once does not automatically cover a state you added later.
7.62$2,6692026-05-31 — Simplified supply report for 2025 data.
2026-07-01 — CAA plan filing to MDE.
Colorado
HB 22-1355
⚠ Obligated — participation unconfirmed
Participation in this state's programme is not confirmed. CAA takes a single registration covering all states, but each state programme still has to list you as a participating producer — registering once does not automatically cover a state you added later.
7.25$2,5372024-10-01 — Original producer registration deadline (passed — late registrants are exposed).
2026-05-31 — Annual supply report for 2025 data.
Minnesota
HF 3911 (Packaging Waste and Cost Reduction Act)
⚠ Obligated — participation unconfirmed
Participation in this state's programme is not confirmed. CAA takes a single registration covering all states, but each state programme still has to list you as a participating producer — registering once does not automatically cover a state you added later.
7.04$2,4642026-05-31 — Simplified supply report for 2025 data.
2029-2032 — Fee phase-in.
Oregon
SB 582 (Recycling Modernization Act)
● Obligated — fees live5.21$1,8232026-04-09 — DEQ published its first quarterly producer status list — 250 producers publicly named as non-compliant.
2026-05-31 — CAA deadline for 2025 supply data (sets 2027 fees).
2026-12-31 — Life-cycle impact evaluation disclosure due for the 25 largest producers by weight.
Maine
LD 1541 / LD 1423
⚠ Obligated — participation unconfirmed
Participation in this state's programme is not confirmed. CAA takes a single registration covering all states, but each state programme still has to list you as a participating producer — registering once does not automatically cover a state you added later.
1.71$5982026-08-03 — Stewardship organization selection milestone.
2026-Q3 — First reporting expected.

Estimated annual fee by state

Hover any bar for the underlying tonnage and rate basis.

California
$16,799
Washington
$3,369
Maryland
$2,669
Colorado
$2,537
Minnesota
$2,464
Oregon
$1,823
Maine
$598

Where the money actually goes

Fees are charged per pound by material, and the spread between the cheapest and the most expensive material is more than twenty to one. The bars below are the chargeable pounds only — the share of your national volume allocated to the seven enacted states — priced at Oregon’s published rates.

Multi-layer laminate / stand-up pouches
$10,726
Glass containers
$4,689
PE film (poly mailers, shrink, bags)
$2,892
Corrugated cardboard (shippers)
$2,291
Mixed / unclassified
$2,264
PVC / PVDC
$2,059
Boxboard / folding carton
$1,792
PET — clear bottles
$1,573
Expanded polystyrene (EPS foam)
$1,259
PP rigid (tubs, closures, jars)
$692

Fee reduction opportunities

What is exposed if nothing changes

Oregon publishes a producer status list every quarter naming non-compliant producers. The first list, on 9 April 2026, named 250 companies.

Data gaps to close before you file

Everything below is a number a regulator would expect you to be able to defend.

What we would do next. Close the gaps above by pulling component specifications from your suppliers, convert your catalogue into a defensible per-SKU packaging bill of materials, and file the state reports on your schedule. Fixed fee, five business days for the data build. Book an assessment — $1,850 · or ask a question first · https://packfile-1bs.pages.dev

Sources