U.S. Packaging EPR Laws Expand in 2025

Seven States Now Require Producers to Register, Report, and Pay for Recycling Systems

As of mid-2025, Extended Producer Responsibility (EPR) laws for packaging have taken hold in seven U.S. states: Oregon, Colorado, California, Maine, Maryland, Minnesota, and Washington. These laws require producers to register with designated authorities, report packaging data, and contribute financially to recycling and waste management systems.

Oregon: Leading the Way

Oregon became the first state to implement packaging EPR under the Recycling Modernization Act (RMA):

• Over 1,700 producers submitted packaging reports by the March 31, 2025 deadline.
• EPR fees are due by July 1, 2025, or within 30 days of receiving an invoice.

This model is setting national expectations for program compliance.

Colorado: Urgent Deadlines

Colorado’s EPR law is entering full implementation, with deadlines fast approaching:

• Producer registration due: July 1, 2025. Missing this could lead to sales bans.
• 2024 packaging data due: July 31, 2025, via the Circular Action Alliance (CAA) portal.
• Fee collection begins: January 2026.
• Penalties: Up to $1,500/day, or $20,000 for repeat violations.

California: Phased Rollout Under SB 54

California resumed its SB 54 implementation in early 2025:

• Regulatory rulemaking is underway.
• Producers must report 2023 data by November 15, 2025.
• The state’s phased timeline aims to balance environmental impact with administrative feasibility.

Other States Advancing EPR Programs

Several states are rolling out their own EPR laws with timelines through 2030:

• Minnesota: CAA named as official PRO; registration due July 1, 2025.
• Maine: Updated system passed in LD 1423 (June 2025) to align with national trends.
• Maryland: Enacted SB 901 (May 2025); funding model begins 2028–2030.
• Washington: SB 5284 (May 2025) targets full implementation by 2030.

These developments mark a growing shift toward harmonized, circular waste systems nationwide.

Checklist: How Producers Can Stay Compliant

To meet the new requirements, producers should:

✅ Register with a Producer Responsibility Organization (PRO), such as CAA
✅ Submit packaging and sales data by state-specific deadlines
✅ Budget and prepare for EPR fee payments (beginning July 2025 or January 2026)
✅ Track enforcement policies to avoid penalties or restricted sales

Why This Matters

As EPR laws expand, inaction could result in fines, restricted market access, or non-compliance penalties. States are prioritizing environmental accountability and pushing for consistent recycling systems across jurisdictions.

Now is the time for producers to act: review packaging systems, ensure timely registrations, and prepare for financial obligations tied to EPR compliance.

Reference: Circular Action Alliance Newsletter