2026 EPR Compliance Calendar: Every Deadline You Need to Know

For producers navigating EPR for packaging, 2026 is the year compliance shifts from preparation to execution across multiple states simultaneously. What follows is a comprehensive, state-by-state calendar of every verified deadline, based on enacted legislation and published regulatory guidance. Clip this, share it with your compliance team, and build your internal milestones around it.

January 2026

Colorado — Producer Fees Due (January 1, 2026). First EPR fee invoices from the Circular Action Alliance (CAA) are payable, calculated on 2024 packaging supply data submitted by July 31, 2025. This is the first time Colorado producers face a financial obligation under HB 22-1355. Producers who missed the October 1, 2024 registration deadline or the July 31, 2025 supply report are already subject to the sales restriction that took effect July 1, 2025.

California Textiles — PRO Plans Due (January 1, 2026). Under SB 707, California's textiles EPR law, Producer Responsibility Organizations must submit compliance plans by this date. While separate from the packaging EPR program under SB 54, companies operating in both sectors should note the overlap in PRO management requirements.

May 2026

Maine — Registration and Reporting (May 31, 2026). Producers must register with Maine's Stewardship Organization and submit estimated 2025 packaging data. Maine's LD 1541 — the nation's first packaging EPR law, signed July 12, 2021 — uses a municipal cost-reimbursement model distinct from the PRO-administered programs in other states. A 2025 amendment narrowed scope to consumer packaging only, excluding B2B and industrial packaging. The PRO selection process is ongoing, with CAA indicating its intent to respond to Maine's RFP.

Oregon — Annual Report Due (May 31, 2026). Producers registered with CAA must submit their second annual supply report under SB 582, covering 2025 data. Oregon's program has been operational since 2024, with fees already being assessed on reported supply data. Non-compliant producers have been barred from selling in Oregon since July 1, 2025, with penalties up to $25,000 per day.

July 2026

Maryland — Producer Registration (July 1, 2026). Under SB 901 (signed May 13, 2025), producers must join a PRO or submit an individual compliance plan. Maryland's unique multi-PRO model distinguishes it from other states where CAA operates as the sole approved PRO. CAA has been selected to serve on the State Producer Responsibility Advisory Council, but the multi-PRO structure means additional organizations may emerge as options.

Minnesota — Ongoing. Producers should already be registered with CAA. The Minnesota Pollution Control Agency confirmed CAA's registration in February 2025, and the PRO membership deadline was July 1, 2025. Minnesota offers no individual compliance option — PRO membership is mandatory under HF 3911. The stewardship plan is due October 1, 2028, but no major 2026 compliance events remain beyond continued membership maintenance.

Washington — Producer Registration (July 1, 2026). Under SB 5284 (signed May 17, 2025), producers must join a PRO or register individually. CAA has been announced as the PRO in Washington. The compliance plan is due October 1, 2028, with full program implementation not expected until January 1, 2030. Washington's sales restriction takes effect March 1, 2029.

September 2026

Maine — First EPR Fee (September 2026). Following May registration and reporting, Maine producers will face their first fee obligation. This marks the operational launch of the nation's oldest EPR packaging law, more than five years after enactment.

Looking Ahead: Key 2027 Dates

California — PRO Membership / Individual Approval (January 1, 2027). The statutory deadline under SB 54 for producers to join CAA or receive individual approval from CalRecycle. This is also when California's sales restriction takes effect — non-compliant producers will be barred from the California market. Given California's market size and the aggressive targets (30% recycling by 2028, 100% recyclable/compostable packaging by 2032, 25% plastic source reduction), this is the single highest-stakes EPR deadline on the horizon.

Harmonized Reporting

One emerging pattern worth noting: May 31 is becoming a de facto harmonized annual supply reporting date across multiple states, with Oregon and Maine both using this date for 2025 data submissions. Amcor has identified this convergence, and producers operating across states should build their data collection and reporting infrastructure around a single annual cycle rather than treating each state's reporting requirement as an independent workstream.

The Full Timeline at a Glance

Sources: Proskauer (Oct 2025); Holland & Knight (Jan 2026); H2 Compliance (Dec 2025); Venable (Oct 2025)

Constellation Insights, a division of Trash Club Ventures, provides strategic regulatory intelligence for brands, investors, and operators navigating the circular economy.