EPR Compliance & California Deadlines

If your company manufactures, imports, or sells packaged products in the United States, it’s important to understand how evolving regulations may affect your operations. Extended Producer Responsibility (EPR) is a policy approach that makes producers responsible for the full lifecycle of their packaging, including its collection, recycling, and disposal. EPR laws are now active in seven states—California, Colorado, Maine, Maryland, Minnesota, Oregon, and Washington—where the designated “producer” (which may be a manufacturer, importer, or brand owner, depending on product registration) is responsible for compliance. Six of these states share a May 31, 2026 reporting deadline, and typical requirements include enrolling in a Producer Responsibility Organization (PRO), reporting packaging data, and paying associated fees.

California also has additional requirements focused specifically on reducing plastic packaging. Producers are required to submit a Source Reduction Report by May 31, 2026, followed by an Individual Source Reduction Plan by August 1, 2026, and must achieve a 25% reduction in plastic packaging from 2023 levels (measured by both weight and component count), including an interim 10% reduction by January 2027. Because the report is due before the full plan, companies may benefit from beginning data tracking early. Non-compliance can result in penalties of up to $50,000 per day, and additional details on fee structures are expected by May 1, 2026.

For additional resources, please see below a recorded webinar on this topic from April 16, along with the presentation materials available for reference.