Seven states have now enacted Extended Producer Responsibility (EPR) laws focused primarily on packaging: California, Colorado, Maine, Maryland, Minnesota, Oregon, and Washington.
So far, five of those states have designated Circular Action Alliance (CAA) as the approved Producer Responsibility Organization (PRO): California, Colorado, Maryland, Minnesota, and Oregon.
Each state is in a different phase of implementing its new EPR law. In general, three steps must be completed in each state before full implementation can occur:
- The state agency must formally implement its rules
- The state agency must approve CAA’s state program plan
- CAA must establish its internal processes and timelines for producer registration, reporting, and payment of fees.
The current progress of each EPR-enacted state is detailed below. For a general overview of EPR laws – including what they cover, who is affected, and some of the problems that have emerged since their passage – see our articles from January, May, and July 2025.
Oregon
Oregon’s Plastic Pollution and Recycling Modernization Act became fully implemented on July 1, 2025.
- Rulemaking: Oregon’s Department of Environmental Quality (DEQ) has implemented its regulations through two rulemaking processes. DEQ is gearing up to do its third rulemaking, which will take place from September 2025 until early 2027. As that process gets started, DEQ is soliciting producer feedback on which materials should be added to the list of covered product exemptions. Feedback can be provided via this form until October 31, 2025.
- Program Plan: DEQ approved CAA’s Oregon Program Plan in February 2025. DEQ approved an amendment to the Oregon Program Plan in September 2025, which provides more detail around Bonus C incentives for reusable or refillable packaging. In August 2025, CAA submitted a second amendment to DEQ for approval, this one focused on Responsible End Markets (an issue that is not directly applicable to producers); public comment on this amendment is open through October 15, 2025.
- CAA’s Producer Process: CAA required producers to register and submit an initial supply report covering 2024 supply into the state by March 31, 2025 (later extended to April 30, 2025). CAA began sending invoices to registered producers in July 2025.
- CAA Financial Report: CAA Oregon submitted its 2025 Financial Report (covering the start-up phase of 2023-2024) to DEQ in July 2025. DEQ is accepting public comments on this report until October 17, 2025.
Colorado
Colorado’s Producer Responsibility Program for Statewide Recycling Act will become fully implemented on January 1, 2026.
- Rulemaking: Colorado’s Department of Public Health and Environment (CDPHE) has implemented its regulations. In August 2025, CDPHE initiated rulemaking regarding the eco-modulation bonus schedule. Public comment on these proposed rules closed on September 28.
- Program Plan: In June 2025, CAA submitted a proposed Colorado Program Plan to CDPHE that includes the amendments previously requested by the agency. Public comment on this Plan closed on September 14, and CDPHE is currently reviewing the Program Plan. CDPHE’s approval decision is expected in December.
- CAA Producer Process: CAA required producers to register and submit an initial supply report covering 2024 supply into the state by July 31, 2025. The dues schedule is expected to be published in late October or early November 2025. CAA is expected to begin sending invoices to registered producers in December 2025.
California
California’s Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54) is expected to be fully implemented on January 1, 2027.
- Rulemaking: After its initial rulemaking attempt failed in March 2025, California’s Department of Resources Recycling and Recovery (CalReycle) re-initiated rulemaking in August 2025 and released draft regulations for public comment. Public comments are due October 7, 2025.
- Program Plan: An initial draft of CAA’s California Program Plan is expected in mid-2026.
- CAA Producer Process: CAA required California producers to register by September 5, 2025. Around September 22, CAA began sending out the California State Interim Addendum for signature by registered producers. CAA is preparing guidance materials to aid in the preparation of supply reports. Initial supply reports cover 2023 data (for baseline purposes only, not for fees) and are due to CAA on November 15, 2025.
- Early Fees: The California law allows CAA to collect early fees to fund the first couple years of its operation. Fee obligations will be based on 2025 supply data (which will be reported in spring 2026) and invoiced in mid-2026.
Maine
Maine’s Stewardship Program for Packaging passed in 2021 and is expected to be fully implemented in 2027.
- Rulemaking: The Maine Department of Environmental Protection (DEP) adopted rules for the program in December 2024 and updated those rules in summer 2025.
- Stewardship Organization: Maine has not yet selected a Stewardship Organization (the terminology used by Maine in place of PRO). CAA has applied to serve in this role. DEP expects to select and contract with a Stewardship Organization in April 2026.
- CAA Producer Process: DEP anticipates that producers will need to register with and provide supply reports to the selected Stewardship Organization in May 2026.
Minnesota
Minnesota’s Packaging Waste and Cost Reduction Act is still early in the process of development and is expected to become fully implemented in 2029. The Minnesota Pollution Control Agency (MPCA) is currently gathering initial data for the program’s development through a needs assessment.
- Rulemaking: MPCA has not commenced rulemaking.
- Program Plan: CAA’s Stewardship Plan is expected in 2028.
- CAA Producer Process: CAA required Minnesota producers to register by July 1, 2025.
- Early Fees: Like California, the Minnesota law allows CAA to collect early fees. The timing of these fees is currently unknown.
Maryland
Maryland’s Packaging and Paper Products Producer Responsibility Plans Act was signed into law in May 2025. The law is in the very early stages of development and no rulemaking has commenced. While CAA has been identified as the PRO, it has not developed a program plan, nor has it developed any producer processes. Producers will likely need to register with CAA by July 2026.
Washington
Washington’s Recycling Reform Act was signed into law in May 2025. The law is expected to become operational in 2030. Rulemaking will begin in 2026. A PRO has not yet been identified.
