If your company ships packaged products into more than one state, you’ve probably noticed that “extended producer responsibility” doesn’t mean the same thing everywhere. California, Oregon, Colorado, Maine, and Minnesota have each passed their own packaging EPR law, and while they share a basic structure — producers fund end-of-life management of their packaging through a producer responsibility organization (PRO) — the timelines, fee models, and exemptions are different enough to trip up anyone assuming one compliance calendar covers all five.
This guide lines up where each state actually stands as of October 2026, what makes each program distinct, and the mistakes most likely to catch a multi-state seller off guard.
Quick Answer
Oregon was first to launch and has been collecting PRO fees since July 1, 2025. Colorado is close behind, with dues underway since early 2026. California’s SB 54 regulations were finalized and took effect May 1, 2026, with a June 1, 2026 producer registration deadline and full program implementation targeted for January 2027. Minnesota is in a multi-year data-gathering and needs-assessment phase, with no fees yet and full compliance not required until 2032. Maine’s program is effectively stalled: as of its August 2026 search for an administrator, no organization had agreed to run it, so registration and invoicing haven’t started.
Where each state stands right now
California (SB 54): After a lengthy rulemaking process, California’s Office of Administrative Law approved the final SB 54 regulations on May 1, 2026. Producers face a June 1, 2026 deadline to either register with Circular Action Alliance (CAA) and submit supply data, register directly with CalRecycle as an independent reporting entity, or apply for the small-producer exemption (roughly under $1 million in California gross sales). Full program implementation — including the PRO’s funded collection and recycling obligations — is still targeted to start January 2027. The law’s statutory targets include cutting covered plastic packaging by 25% and reaching a 65% recycling rate by 2032, with all covered packaging recyclable or compostable by that date. Shortly after the rules were finalized, environmental groups announced plans to challenge parts of them, so some details could still shift.
Oregon: The first operating packaging EPR program in the U.S., running since July 1, 2025. Producers registered with CAA and reported 2024 packaging data by March 31, 2025, and PRO fees have been due since the program’s July 2025 launch. Oregon also maintains a public noncompliance registry for producers who miss obligations.
Colorado: Signed into law in 2022 (HB 22-1355), with CAA’s program plan approved by the state in December 2025. Producers began paying dues in early 2026, putting Colorado’s rollout on roughly the same track as Oregon’s, just about a year behind.
Maine: Ironically the first state to pass a packaging EPR law (2021), but the furthest behind in practice. Maine ran its own stewardship-organization search rather than defaulting to CAA, and in August 2026 received zero proposals — CAA said the RFP’s scope didn’t match its operating model. The state is now reassessing its approach, with no firm registration date.
Minnesota: Enacted in 2024, with CAA confirmed as the designated PRO in early 2025. Producers were required to register with CAA by July 1, 2025, and that deadline has passed. 2026 is focused on supply-chain data reporting and a needs assessment due by the end of the year; CAA must finalize a stewardship plan by October 2028, producers need executed agreements with the PRO by January 2029, and full compliance (recycling and composting services available per the approved plan) is required by January 2032. No fees are being collected yet.
What actually differs between the five programs
Funding model: Maine’s law makes producers responsible for the full cost of municipal packaging recycling once it’s running — the most aggressive funding structure of the five. Minnesota phases producer costs in gradually over a much longer runway, stretching toward full compliance in 2032. Oregon and Colorado use a more conventional dues-based PRO funding structure from the start, and California’s fees begin once full implementation starts in 2027.
Substantive targets: California’s SB 54 is the only one of the five with hard numeric packaging-reduction and recyclability targets written into the statute — phased plastic source-reduction goals building to 25% by 2032, recycling-rate targets rising to 65% by 2032, and a requirement that covered packaging be recyclable or compostable by that date. Oregon, Colorado, Maine, and Minnesota are primarily funding-and-collection programs rather than source-reduction mandates, though needs assessments in several states may add targets later.
Small-business exemptions: Oregon and Colorado both exempt producers below roughly $5 million in global annual revenue (Colorado’s figure adjusts annually and is now slightly higher). Maine’s exemption is tighter and multi-layered — under $2 million in in-state revenue (a temporarily higher $5 million threshold applies in the program’s early years), or under one ton of covered packaging sold per year. Minnesota exempts producers below $2 million in global revenue or under one ton of packaging annually. California’s threshold is the lowest of the five, at roughly $1 million in California gross sales. Check each state’s current exemption rules directly rather than assuming they match.
Who runs it: Circular Action Alliance (CAA) is the designated PRO in California, Oregon, Colorado, and Minnesota (as well as Maryland and Washington), which means one registration can cover reporting for most of these states. Maine is the exception — with no stewardship organization in place as of late 2026, there’s currently no CAA-equivalent entity to register with there.
Tips / Common Mistakes
Don’t assume one CAA registration automatically satisfies every state’s reporting requirement — each state still has its own deadlines, data formats, and fee schedule even when CAA is the administrator. Track each state separately on your compliance calendar.
Several states converge on dates in the May-to-June window for annual data reporting or registration, which makes it easy to treat that as a single multi-state deadline — but confirm the exact requirement for each state you sell into, since fee due dates and registration windows don’t all line up the same way.
If you were working from older coverage of California’s SB 54, double-check it: the regulations were withdrawn and revised earlier in 2026, then finalized and took effect May 1, 2026, with a June 1, 2026 registration deadline. Timelines that circulated before that approval may be outdated. Check CalRecycle’s current guidance before acting on older articles.
If you operate in Maine, don’t wait for a CAA-style registration portal to appear — the program’s administrator situation was unresolved as of mid-to-late 2026, so the right move is to monitor Maine DEP’s own announcements rather than assuming the Oregon/Colorado process will repeat there.
Explore more: More packaging compliance guides.
State packaging EPR laws FAQs
Do I have to comply with all five states’ EPR laws if I sell nationally?
You only owe obligations in a state if you sell or distribute covered packaging there and exceed that state’s small-producer exemption threshold. A national seller above the revenue thresholds would likely need to register in each active program state separately.
Is Circular Action Alliance the PRO in every one of these states?
CAA administers the programs in California, Oregon, Colorado, and Minnesota. Maine is the exception — it ran its own administrator search rather than defaulting to CAA, and as of August 2026 had no stewardship organization in place.
Which state’s packaging EPR program is furthest along?
Oregon’s, by a clear margin — it launched July 1, 2025, and has been collecting PRO fees since. Colorado is next, with dues underway since early 2026, and California’s regulations took effect May 1, 2026 with full implementation set for January 2027. Minnesota and Maine are furthest from collecting fees.
Why is Maine’s program stalled when it passed its EPR law before the others?
Maine chose to solicit its own stewardship organization rather than using CAA. Its request for proposals, open through August 2026, received no bidders — CAA stated the RFP’s scope didn’t align with how it operates in other states — leaving Maine without an administrator.
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Photo: Greenville, NC / Public domain, via Wikimedia Commons.