Prepared 27 July 2026 · Seven enacted US packaging EPR programmes ·
Profile: Pet food and treats, $41,000,000 revenue, mixed channel mix
Obligated
7
states, on this profile
Too close to call
0
within 25% of a threshold
Fees, states charging now
$17,937
per year, screening estimate
Once all seven are live
$124,482
per year, on today's volumes
How this number was reached, so you can argue with it. Your category implies roughly
40 lb of packaging per $1,000 of revenue, adjusted for a mixed channel mix.
That gives about 878 tonnes placed on the US market per year. Each state's share
is allocated by population, which is the fallback method referenced in PRO guidance when a producer
cannot report actual state-level shipments. Fees apply Oregon's published 2026 per-material rates;
no other state has published a per-material schedule yet. The packaging-intensity assumption carries
roughly ±35%, which is why anything within 25% of a threshold is marked borderline rather than
decided.
State-by-state determination
California · SB 54 (Plastic Pollution Prevention and Packaging Producer Responsibility Act)
⚠ Obligated
in-state gross sales of $4,723,200 against a $1,000,000 threshold — over. Rule: exempt if EITHER test is under threshold.
Estimated fee if obligated: $69,110/yr — fees begin 2027-01-01
What to do next
Register in CalRecycle's PEPRS system. Do this even if you believe you are exempt — California's small-producer exemption must be APPLIED FOR, not merely qualified for.
If you are a participating producer, submit the baseline producer report (2023 data) and your individual source reduction plan.
Understand that fees begin January 2027 and are calculated from the data reported during 2026. Accuracy this year is next year's invoice.
Exposure if ignored: CalRecycle enforcement; producers can be found delinquent by the PRO and referred to the state.
Washington · E2SSB 5284 (Recycling Reform Act)
⚠ Obligated
global revenue of $41,000,000 against a $5,000,000 threshold — over. Rule: exempt if EITHER test is under threshold.
Estimated fee if obligated: $13,858/yr — fees begin 2029-07-01
What to do next
Join Circular Action Alliance — Washington producers were required to do so by 1 July 2026.
Fee obligations do not begin until 2029–2030, so the near-term obligation is registration and reporting only.
Exposure if ignored: Minimum $1,000 for a first violation, escalating.
Maryland · SB 901
⚠ Obligated
global revenue of $41,000,000 against a $2,000,000 threshold — over; an estimated 16.06 tonnes of covered material supplied into the state against a 1 tonne threshold — over. Rule: exempt if EITHER test is under threshold.
Estimated fee if obligated: $10,978/yr — fees begin 2028-01-01
What to do next
Register with Circular Action Alliance and file the simplified supply report.
Fees begin in 2028. Penalties escalate at $5,000 / $10,000 / $20,000 per violation.
Exposure if ignored: $5,000 first violation; $10,000 second; $20,000 each subsequent violation.
Colorado · HB 22-1355
⚠ Obligated
global revenue of $41,000,000 against a $500,000 threshold — over; an estimated 15.27 tonnes of covered material supplied into the state against a 1 tonne threshold — over. Rule: exempt if EITHER test is under threshold.
Estimated fee if obligated: $10,438/yr — charging now
What to do next
Register with Circular Action Alliance if you have not. The original deadline was 1 October 2024, so a late registration is better than a missing one.
Check whether you qualify for Colorado's low-volume producer track (roughly under $5.5M revenue) — it is a materially lighter obligation than full producer status.
Fees are live as of January 2026, so an unreported year is an unbilled year, not a free one.
Exposure if ignored: Enforcement by CDPHE; producers below ~$5.5M revenue may register as low-volume producers rather than pay full fees.
Minnesota · HF 3911 (Packaging Waste and Cost Reduction Act)
⚠ Obligated
global revenue of $41,000,000 against a $2,000,000 threshold — over; an estimated 14.83 tonnes of covered material supplied into the state against a 1 tonne threshold — over. Rule: exempt if EITHER test is under threshold.
Estimated fee if obligated: $10,139/yr — fees begin 2029-02-01
What to do next
Register with Circular Action Alliance and file the simplified supply report.
Fees phase in from 2029. The penalty ceiling is the highest of the seven states — up to $100,000 per day for successive violations — so registration is not a low-stakes item.
Exposure if ignored: Up to $100,000 per day for successive violations.
Oregon · SB 582 (Recycling Modernization Act)
⚠ Obligated
global revenue of $41,000,000 against a $5,000,000 threshold — over; an estimated 10.97 tonnes of covered material supplied into the state against a 1 tonne threshold — over. Rule: exempt if EITHER test is under threshold.
Estimated fee if obligated: $7,499/yr — charging now
What to do next
Register with Circular Action Alliance. Registration is free and is the first legal obligation — it is separate from reporting and separate from paying.
Confirm you appear on DEQ's producer status list. DEQ republishes it quarterly and names producers who have not complied; the first list, on 9 April 2026, named 250 companies.
Report your 2025 supply data through CAA. This is what sets your 2027 fee.
Exposure if ignored: Class 1 violation, civil penalties up to $25,000 per day; Oregon DOJ may bar sale of the producer's products in state.
Maine · LD 1541 / LD 1423
⚠ Obligated
global revenue of $41,000,000 against a $2,000,000 threshold — over; an estimated 3.60 tonnes of covered material supplied into the state against a 1 tonne threshold — over. Rule: exempt if EITHER test is under threshold.
Estimated fee if obligated: $2,460/yr — fees begin 2026-12-01
What to do next
Maine runs a state-administered model rather than the CAA producer responsibility organisation model used in the other six states; watch the stewardship organisation selection.
First reporting is expected in Q3 2026.
Exposure if ignored: Maine DEP enforcement.
Your next eighteen months
2026-08-01
California
Individual source reduction plans due to CAA.
2026-08-03
Maine
Stewardship organisation selection milestone.
2026-Q3
Maine
First reporting expected.
2026-Q3
Oregon
Next quarterly DEQ producer status list published.
2026-10-01
All CAA states
Registration remains open and free; late registration is still better than none.
2026-12-31
Oregon
Life-cycle impact evaluation disclosure due for the 25 largest producers by weight.
2027-01-01
California
Fees begin. Calculated from data reported during 2026. 10% plastic source reduction target.
2027-Q2
OR / CO / CA / MN / MD / WA
Annual supply reports for 2026 data — the main cycle of the year.
2028
Maryland
Fees begin.
2029
Minnesota, Washington
Fee phase-in begins.
Three things worth knowing that cost you nothing
Registering with the producer responsibility organisation is free. You do not need us, or
anyone, to do it. It is also the first legal obligation in every CAA state and it is separate from
reporting and from paying fees. If you do one thing after reading this, do that.
In California, being small is not the same as being exempt. CalRecycle requires you to
register in PEPRS and then apply for the small-producer exemption. Companies that quietly
concluded they were too small are the ones most likely to be wrong.
Capture material and gram weight together, the first time. When you ask a supplier for a
component specification, ask for the resin or fibre grade and the unit weight in grams in the
same message. Going back a second time for weights is what turns a two-week job into a four-month
one, and it is the single most common reason first submissions run late.
What this document does not do
It determines whether you are obligated. It does not produce a filing.
A state report is per-SKU: every packaging component, identified by material and weighed in grams. The
figures here come from a category average, which is enough to decide whether you are in scope and
nowhere near enough to submit.
If you want the filing-ready dataset — your actual catalogue, component by component,
with the supplier chase run for you — that is our assessment, and the $149 you paid for this comes off
it: book it here. If you would rather build it in-house, the three points
above are the ones that matter most, and we are glad to answer a question by email either way —
71watson17@gmail.com.