State of Paper and Packaging EPR Laws in the U.S.
by Sara Osorio, Environmental, Health and Safety Affairs Coordinator Feb 5, 2026

Extended Producer Responsibility (EPR) legislation is expanding across the U.S., with seven states now having passed packaging EPR laws and each currently in a different phase of implementation. While program details and covered products (e.g., packaging or printed paper) vary by state, the overall impact is consistent: EPR is increasing the focus on packaging design, material performance, and data reporting requirements across the supply chain. EPR is not a new concept, and programs already exist in many states for other product categories, including electronics (e-waste), batteries, paint, mattresses, and pharmaceuticals/sharps.

EPR packaging and printed paper laws are likely to create similar pressures and opportunities for printers and packaging converters. Companies can expect to see migration to new packaging redesigns and versioning as brand owners adjust materials and on-pack messaging to meet recyclability or compostability expectations. In addition, there will be increased requests for documentation to support volumes produced and sustainability claims. At the same time, rising compliance demands may increase customer price sensitivity, putting added emphasis on reducing waste, tightening overruns, and improving production efficiency.

These programs also make reporting and data management a recurring requirement. Co-modulated fee structures may accelerate shifts away from harder-to-recycle materials. Overall, material choices and package design will be more closely tied to performance expectations that support recyclable, reusable, or compostable packaging formats.

Below are the key elements and important dates for each state:

California – SB 54

  • Covers single-use packaging and service ware. Material types that prove a 70% recycling rate are exempt.
  • Circular Action Alliance (CAA) approved as Producer Responsibility Organization (PRO) on January 8, 2024.
  • Producer registration deadline was September 5, 2025.
  • CalRecycle recently issued revised proposed regulations to make changes that improve clarity and help with implementation. Comments will be open until February 13, 2026.
  • On track to begin full implementation in January 2027.

Colorado – HB22-1355

  • Covers single-use packaging AND printed paper.
  • CAA’s final plan approved as PRO on May 1, 2023.
  • Producer registration deadline was October 1, 2024.
  • Final plan was approved in December 2025 by CDPHE.
  • Fee payments and full compliance started on January 1, 2026.

Maine – LD 1542

  • Covers single-use packaging.
  • DEP is expected to contract with a Stewardship Organization (SO) in Spring 2026.
  • Producer deadline to register and report is May 2026.
  • Program is expected to be fully operational in 2027.

Maryland – SB 901

  • Covers single-use packaging AND printed paper.
  • Maryland allows multiple PRO’s and CAA was initially approved on October 23, 2023.
  • Producers are required to register with the Maryland Department of Environment by July 1, 2026.
  • Data reporting begins July 1, 2029.

Minnesota – HF 3911

  • Covers single-use packaging AND printed paper.
  • CAA approved as PRO on February 18, 2025. Deadline to join PRO was July 1, 2025.
  • Needs assessment will be done in 2026 to determine the scope of the program.
  • Program is expected to begin early 2029.

Oregon – SB 582

  • Covers single-use packaging AND printed paper.
  • The Oregon Department of Environmental Quality (DEQ) approved CAA’s plan on February 21, 2025.
  • Producer registration deadline was March 31, 2025.
  • Program began July 1, 2025.
  • Currently being challenged in court.

Washington – SB 5824

  • Covers single-use packaging AND paper.
  • Producers must appoint one or multiple PRO’s by January 1, 2026.
  • PRO must register with the state by March 1, 2026 on behalf of producers.
  • Needs assessment must be completed by Ecology by December 31, 2027.
  • Program is expected to be fully operational on January 1, 2030.

Most of these state EPR laws are primarily designed around consumer/residential packaging so typical B2B transport packaging used strictly within commercial supply chains (like pallets, strapping, or warehouse-only stretch wrap) is often outside the core intent. However, B2B packaging can still be captured depending on how a state defines “covered material” and whether that packaging is consumer-facing or likely to enter the residential waste stream. Minnesota is the clearest example of a state that explicitly recognizes this distinction through specific commercial/B2B exemptions, while states like Washington and Oregon are more closely tied to residential packaging and municipal recycling systems. In California, PRINTING United Alliance submitted comments to CalRecycle on February 04, 2026, urging the agency not to include B2B packaging in SB 54 regulations.

Looking ahead, packaging and printed paper EPR is likely to continue expanding beyond the seven states highlighted above. In 2026, New Hampshire, New Jersey, and Wisconsin have already introduced packaging EPR legislation, signaling continued momentum. At the same time, EPR proposals and active policy discussions remain ongoing in states such as Massachusetts, New York, Rhode Island, and Virginia, reinforcing that printers and packaging converters should expect continued legislative activity and an increasingly complex multi-state compliance landscape in the years ahead. The Alliance is closely monitoring developments in these states and will continue providing updates as new bills advance and program requirements become clearer.

In this article, Sara Osorio, Coordinator, EHS Affairs, PRINTING United Alliance, discusses paper and packaging EPR state laws. More information on EPR can be found at Business Excellence-EHS Affairs, or reach out to Sara directly if you have questions about how these issues may affect your business: sosorio@printing.org.

To become a member of the Alliance and learn more about how our subject matter experts can assist your company with services and resources such as those mentioned in this article, please contact the Alliance membership team: 888-385-3588 / membership@printing.org.

Our editorial content is edited and approved by humans. While staff may use AI tools in the brainstorming or research stage to generate ideas, provide background context, or suggest phrasing, humans always verify facts, evaluate context, and make final decisions. We may also use AI to enhance user experiences (e.g., creating summaries or SEO suggestions), but any such output is reviewed by humans and, when appropriate, labeled as AI-assisted.

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Sara Osorio Environmental, Health and Safety Affairs Coordinator
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Sara Osorio is the Environmental, Health and Safety (EHS) Affairs Coordinator at PRINTING United Alliance. Her primary responsibility is to assist members with EHS regulatory compliance, sustainability, and EHS consulting. Sara also monitors the EHS regulatory activities at the federal and state-level that impact the printing industry including those occurring at Environmental Protection Agency (EPA), the Occupational Health and Safety Administration (OSHA), the Department of Transportation (DOT), and other agencies. She develops guidance material for members, gives presentations, and writes articles on EHS regulations and sustainability issues. She also supports the Sustainable Green Printing Partnership and Alliance members in their efforts to certify printing operations in sustainable manufacturing.

Sara received a Bachelor of Science in Environmental Studies from Florida International University and is pursuing and Master of Science in Sustainable Management from the University of Wisconsin – Green Bay.

Speaking Topics:

  • Regulatory compliance and sustainability
  • Webinars on a wide variety of EHS related topics
  • Customized seminars and workshops
  • Employee training on safety and environmental compliance

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