U.S. Packaging EPR: Prepare for May 31 Reporting Deadline
State Extended Producer Responsibility (EPR) laws for packaging are now live which include compliance obligations for many producers selling or distributing packaged goods across the United States. A key milestone for packaging EPR compliance in 2026 is the May 31 deadline for harmonized annual supply reporting based on 2025 data in states with mature or emerging EPR programs.
This update breaks down state-specific obligations tied to the May 31 deadlines, outlines other key state timelines, covers the status of California’s SB 54 implementation, and lays out concrete steps producers must take now to meet expanding EPR responsibilities.
U.S. Packaging EPR Reporting Deadlines and State Obligations
Colorado — May 31, 2026 Reporting Deadline
Colorado’s EPR law for packaging is House Bill 22–1355, which became law in 2022 and is overseen by the Colorado Department of Public Health and Environment (CDPHE). Producers must join a Producer Responsibility Organization (PRO) (Circular Action Alliance), which will fund and manage the recycling of packaging materials and printed paper.
What Producers Must Do in Colorado
- Prepare and submit 2025 packaging supply data by May 31, 2026, to CAA.
Oregon — May 31, 2026 Reporting Deadline
Oregon’s packaging EPR program under the Plastic Pollution and Recycling Modernization Act (Senate Bill 582) requires producers to submit annual supply reports to the designated PRO (Circular Action Alliance). This reporting deadline follows an established program launch in 2025, with fees and compliance obligations already in effect.
What Producers Must Do in Oregon
- Prepare and submit 2025 packaging supply data by May 31, 2026, to CAA.
- Ensure packaging material definitions align with Oregon’s covered material categories.
Maryland — May 31, 2026 Reporting Deadline
Maryland’s Packaging Producer Responsibility Act (SB 901) requires producers to engage with an approved PRO and submit packaging data by May 31, 2026, based on 2025 supplier data. Registration with a PRO must occur by July 1, 2026.
What Producers Must Do in Maryland
- Register with an approved PRO (CAA) before July 1, 2026.
- Submit Simplified Supply Report for 2025 packaging supply data by May 31, 2026.
Minnesota — May 31, 2026 Reporting Deadline
Minnesota’s packaging EPR program obligations, enacted through the Packaging Waste & Cost Reduction Act (HF 3911 / SF 3877), are solidifying around a May 31, 2026 reporting deadline for 2025 packaging data. Producers should verify reporting requirements and PRO registration status before submitting data.
What Producers Must Do in Minnesota
- If not already, be sure to register with a PRO (CAA), as registrations are now open.
- Submit Simplified Supply Report for 2025 packaging data by May 31, 2026.
Washington — May 31, 2026 Reporting Deadline
Under Washington’s packaging EPR law (Packaging Extended Producer Responsibility Act, SB 5284), producers must register with a PRO by July 1, 2026 and prepare to submit annual reporting that aligns with the harmonized May 31, 2026, reporting date.
What Producers Must Do in Washington
- If not already, be sure to register with a PRO (CAA), as registrations are now open.
- Prepare and submit Simplified Supply Report for 2025 packaging supply data by May 31, 2026.
Other States and Key Timelines
Maine — Reporting/Registration Targeted for 2026
Maine’s packaging EPR statute (LD 1541, first enacted in 2021) is still phasing in implementation, including selection of a stewardship organization and producer onboarding, but reporting readiness and data submission are expected around Q3 2026.
What Producers Must Do in Maine
- Register with a Stewardship Organization (CAA) by May 2026
- Monitor the SO portal launch and readiness to report packaging data.
- Prepare to submit Simplified Supply Report around Q3 2026 (date TBD).
California SB 54: Rulemaking Reset but Obligations Continue
California’s EPR law, SB 54, remains one of the most ambitious packaging EPR laws in the U.S., but is experiencing regulatory delays. CalRecycle recently withdrew its proposed regulations for SB 54 from Office of Administrative Law review to revise clarity and address food and agricultural packaging exemptions, with a new 15-day public comment period from January 29 to February 13, 2026.
Despite this delay, statutory deadlines remain unchanged and the program is expected to fully launch in January 2027 under existing timelines.
Implications for California Producers
- Baseline reporting of 2023 packaging data was due November 15, 2025, despite regulatory uncertainty. Producers should retain this data and be prepared to resubmit within 30 days of final rule adoption.
Why Producers Need to Prepare Now
State packaging EPR deadlines, especially the May 31, 2026, reporting obligations, are approaching quickly and will dictate compliance readiness throughout 2026 and beyond. Failing to meet reporting or registration requirements can lead to fines, administrative actions, or sales restrictions in state markets.
“Producers should view the May 31 reporting cycle as a critical operational milestone. Delays in one state’s rulemaking — such as California’s SB 54 revisions — do not pause compliance responsibilities elsewhere. Having data systems and internal ownership aligned now positions companies to avoid penalties and meet obligations across multiple states.”
— Kristen Kelly, RLG
How RLG Supports U.S. Packaging EPR Compliance
U.S. packaging EPR laws create real operational challenges for producers, particularly around reporting deadlines, evolving state requirements, and data readiness. RLG helps producers manage these obligations with practical, end-to-end support.
- Horizon Scanning tracks changing EPR deadlines and regulatory shifts, including California’s SB 54 rulemaking reset, helping producers avoid missed or misunderstood obligations.
- EPR Assessments clarify which SKUs and packaging materials are in scope across states and identify gaps in supplier data and state-level alignment.
- Packaging Data Health Services clean and standardize packaging datasets, reducing SKU audit burdens and material classification errors ahead of mandatory reporting.
- Environmental Compliance Management centralizes multi-state EPR obligations, minimizing double-counting risks and easing coordination with PRO reporting portals.
Book a confidential, fifteen-minute discovery call with RLG to start preparing for May 31 packaging EPR deadlines and build a practical compliance roadmap.
Disclaimer: This content is for informational purposes only and should not be considered legal advice. Laws are subject to interpretation and change without notice, so always consult with professional advisors and refer to primary sources. Content is accurate as of publication date but may not be regularly updated.
Editor’s note: This article has been reviewed by EPR expert Kristen Kelly.
