Six States Face Packaging EPR Reporting Deadline on May 31

Companies that produce or sell packaged goods and, in some cases, printed paper-based products in the U.S. are facing a major compliance deadline. Six states now require Extended Producer Responsibility (EPR) reporting submissions by May 31, 2026.

The reporting deadlines are as follows:

*Maine has also passed packaging EPR legislation but is operating on a different implementation timeline.

What needs to be reported?

California, Colorado, and Oregon require producers to file detailed Annual Supply Reports that include SKU-level and component-level packaging data. Meanwhile, producers in Minnesota, Maryland, and Washington must submit Simplified Supply Reports using aggregated material weight data.

The difference is significant. The detailed reports submitted in California, Colorado, and Oregon will be used to calculate producer fees starting in 2027, making accurate data collection especially important. Minnesota, Maryland, and Washington are not expected to begin assessing fees until at least 2028.

Who is Considered a Producer?

Under packaging EPR laws, a “producer” is typically the company responsible for introducing packaged products into a state market, including brand owners, manufacturers, importers, or distributors. Because producer definitions vary by state, companies should carefully review how each law applies to their specific operations, packaging formats, and distribution channels.

In states such as California and Oregon, packaging laws may also apply to certain B2B packaging materials, including secondary and tertiary packaging used for shipping and distribution. As a result, printing operations and packaging manufacturers shipping products into or within those states could be classified as producers and may be responsible for reporting packaging data and participating in compliance programs.

How to Prepare?

With packaging EPR deadlines approaching, printers, converters, and packaging suppliers should begin preparing now. Companies serving customers across multiple states should:

• Confirm applicability and CAA registration if necessary
• Understand customer expectations
• Review packaging data already being collected
• Evaluate B2B exposure in each state

Printers, converters, and packaging suppliers should not assume that EPR laws only affect consumer brands as they may be classified as a producer.  Companies throughout the packaging supply chain will likely face increasing pressure to provide accurate packaging data and support customer compliance efforts, with major reporting deadlines now in place and additional fee structures expected in the coming years

Preparing early by improving data collection, understanding state requirements, and reviewing packaging classifications can help companies reduce compliance risks and better position themselves as regulations continue to evolve.

In this article, Sara Osorio, Manager, EHS & Sustainability, PRINTING United Alliance, discusses upcoming state EPR deadlines. More information on sustainability 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.

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