Extended Producer Responsibility (EPR) continues to transform the packaging landscape across the U.S., and brands in health & wellness, beauty, personal care, and essential oils are feeling the impact more each month. While Carow Packaging is not an EPR consultant nor a compliance service provider, our customers rely on us for clarity as regulations evolve. This guide breaks down what’s happening, what matters for product manufacturers and fillers, and where to go for the most accurate, up‑to‑date information.
What Is Extended Producer Responsibility (EPR)?
Extended Producer Responsibility (EPR) is a policy framework that shifts the financial and operational responsibility for packaging waste from municipalities and taxpayers to the companies that place packaged products into a state’s marketplace. Current policy analyses show that EPR programs increasingly include producer fees, detailed data reporting, packaging‑design requirements, and potential restrictions on non‑recyclable formats, all of which carry long‑term business implications for brands and suppliers.
Where Is Packaging EPR Active Today?
As of 2026, seven U.S. states have enacted formal packaging EPR legislation:
- • Maine
- • Oregon
- • Colorado
- • California
- • Minnesota
- • Maryland
- • Washington
Each state program follows its own timeline and implementation model, with additional states actively exploring EPR legislation for 2026–2027.
Below is a high-level overview of current state requirements most relevant to producers.
State-by-State EPR Overview for Producers
Maine — Reporting and Registration Targeted for 2026
Maine’s packaging EPR law (LD 1541), enacted in 2021, continues to phase into implementation.
What producers should monitor in Maine:
- • Selection and contracting of a Producer Responsibility Organization (PRO)
by the Maine Department of Environmental Protection (DEP) - • Launch of the PRO reporting portal
- • Preparation for a Simplified Supply Report, expected around Q3 2026
(date TBD)
Oregon — May 31, 2026 Reporting Deadline
Oregon’s program operates under the Plastic Pollution and Recycling Modernization Act (SB 582) and is administered by Circular Action Alliance (CAA).
What producers must do in Oregon:
- • Submit 2025 packaging supply data by May 31, 2026
- • Confirm packaging materials align with Oregon’s
covered material definitions
Colorado — May 31, 2026 Reporting Deadline
Colorado’s packaging EPR law (HB 22–1355) is overseen by the Colorado Department of Public Health and Environment (CDPHE).
What producers must do in Colorado:
- • Submit 2025 packaging supply data by May 31, 2026 through CAA
California — May 31, 2026 Reporting Deadline
California’s SB 54, the Plastic Pollution Prevention & Packaging Producer Responsibility Act, includes some of the most comprehensive EPR requirements in the U.S.
What producers must do in California:
- • Submit 2025 packaging supply data by May 31, 2026
- • Ensure packaging aligns with California’s covered material categories
- • Prepare for long-term goals, including:
- – 100% recyclable or compostable packaging
- – 25% reduction in single-use plastic by 2032
Minnesota — May 31, 2026 Reporting Deadline
Minnesota’s Packaging Waste & Cost Reduction Act (HF 3911 / SF 3877) continues to finalize reporting mechanics.
What producers must do in Minnesota:
- • Register with a PRO (CAA) if not already enrolled
- • Submit a Simplified Supply Report for 2025 data by May 31, 2026
Maryland — May 31, 2026 Reporting Deadline
Maryland’s Packaging Producer Responsibility Act (SB 901) establishes both reporting and registration timelines.
What producers must do in Maryland:
- • Submit 2025 packaging supply data by May 31, 2026
- • Register with an approved PRO by July 1, 2026
Washington — May 31, 2026 Reporting Deadline
Washington’s Packaging Extended Producer Responsibility Act (SB 5284) aligns with the harmonized May 31 reporting timeline.
What producers must do in Washington:
- • Register with a PRO by July 1, 2026
- • Submit 2025 packaging supply data by May 31, 2026
Circular Action Alliance (CAA): The Compliance Hub for Most States
Most U.S. packaging EPR programs have designated Circular Action Alliance (CAA) as the Producer Responsibility Organization (PRO).
Key points for producers:
- • Registration with CAA is free
- • Producers must:
- – Create an account
- – Sign the Producer Participation Agreement (PPA)
and applicable state addenda - – Submit packaging data by each state’s deadline
For brands selling into multiple EPR states, CAA registration is foundational.
What Packaging Data Will Producers Need?
While requirements vary by state, most EPR programs require detailed packaging information, including:
- • Material safety and composition data
- • Component-level recyclability summaries
- • Packaging weights and technical drawings
Industry experts note that brands—particularly those in beauty and personal care—should prepare for more complex data tracking due to multi‑material components and varied SKU structures. Early investment in accurate packaging data systems can help reduce compliance risk and support long-term sustainability goals.
How Carow Packaging Supports EPR-Related Reporting
Carow Packaging does not provide EPR interpretation or compliance services. However, we support our customers by supplying the packaging data and transparency needed to navigate evolving requirements.
We assist by:
- • Providing detailed material and component specifications
- • Supplying accurate weight and configuration data
- • Offering packaging options with improved recyclability profiles
- • Supporting teams evaluating packaging changes driven
by sustainability goals
Our role is to help ensure you have reliable, consistent packaging information as regulations change.
Staying Ahead of EPR with Carow Packaging
EPR legislation continues to evolve rapidly. Carow Packaging is committed to monitoring regulatory developments and sharing relevant insights that impact our customers.
As states release new guidance and deadlines approach, we’ll continue sharing relevant insights to help support your packaging strategy.
