Washington EPR Deadline Set

Washington has confirmed December 15, 2025 as the official registration deadline for producers under the state’s new Extended Producer Responsibility (EPR) program. Companies selling covered packaging, paper products, and food-service ware in Washington must register by this date to maintain market access.

Mandatory PRO Appointment by January 1, 2026

Beginning January 1, 2026, every producer of covered materials must appoint a Producer Responsibility Organization (PRO) or develop an independent compliance plan. Producers choosing the Circular Action Alliance (CAA) as their PRO must register through CAA’s Producer Portal and select “Washington” before the December 15 deadline.

Following producer registration, PROs must formally register with the Washington Department of Ecology by March 1, 2026.

What Materials Are Covered?

The Washington EPR law applies to a wide range of packaging and paper materials, including:

a. Packaging and paper products such as cartons, wrapping, cardboard
b. Food-service ware and disposable packaging (paper or plastic)
c. All packaging associated with consumer goods, regardless of material (paper, plastic, glass, metal)

Companies that manufacture, import, distribute, or sell products with these materials in Washington may be considered obligated “producers.” CAA will assist in determining producer status.

CAA’s Role if Appointed PRO

If selected as the implementing PRO, CAA will:

i. Develop a statewide Program Plan for collection, recycling, composting, and processing
ii. Work with municipalities and waste-service providers to streamline recycling systems
iii. Provide detailed reporting, fee structures, and compliance guidance once regulations are finalized

Important Dates for Washington EPR Program

Recommended Next Steps for Producers

Producers are advised to:

1. Confirm whether their products fall under Washington’s “covered materials” definition
2. Register with CAA before Dec. 15, 2025 if selecting CAA as the PRO
3. Use the correct legal entity (EIN) during registration
4. Monitor CAA updates on reporting requirements, supply-chain data, and fee structures as regulations progress

Washington’s EPR program marks a significant shift toward a unified, producer-funded recycling framework, with major compliance milestones beginning in 2025 and full implementation targeted for 2030.

Reference: Circular Action Alliance