Packaging producers in Washington and Maryland have until July 1 to register with a producer responsibility organization (PRO), demonstrating how rapidly US packaging EPR is scaling from legislation to on-the-ground implementation.
Producers that have not yet registered are encouraged to do so by June 30. Circular Action Alliance (CAA) is the designated PRO in both states.
CAA reported supporting more than 33,000 national producer accounts across its six states as of year-end 2025. State-by-state breakdowns for Washington and Maryland have not been released.
Seven states now have packaging EPR laws in place. CAA operates as the approved PRO in six of them, the only organization to hold that status across multiple states. Colorado recognizes the Lubricants Packaging Management Association as an independent PRO specifically for petroleum and automotive packaging. Maine’s program remains in rulemaking and the state has not yet selected a PRO.
“We are honored to be implementing Washington’s program and look forward to collaborating with producers, service providers and communities across the state,” said Jeff Fielkow, CAA CEO, in a statement. “Drawing on our experience implementing EPR programs in multiple states, we are focused on delivering practical, consistent solutions that work for Washington’s recycling system.”
Breaking down the deadlines
In Washington, producers of residential packaging, paper products and food serviceware must join a registered PRO or register individually under SB 5284 by July 1.
The law was designed in part to address a gap in recycling access, with only 58% of jurisdictions in the state currently providing curbside collection. While missing the July 1 deadline carries no immediate penalties, producers that remain unregistered after the date are barred from introducing covered materials into the state starting March 2029. CAA’s next deadline is a one-time payment to the Department of Ecology due September 1.
“Today we are all celebrating progress to reduce pollution, improve recycling rates, and divert materials away from landfills,” said Sen. Liz Lovelett, the bill’s sponsor, in a statement shortly following the bill’s approval.
In Maryland, CAA must file its registration with the state Department of the Environment by July 1, including a list of member producers.
State EPR regulations took effect May 25, following passage of SB 901 last year. Maryland producers won’t be invoiced for fees based on their supply reports, with the data being utilized for future program budgets. Fee reimbursements won’t begin until July 1, 2028.
Chaz Miller, a board member of the Maryland Recycling Network, called SB 901 a stronger bill than most that have passed in other states but raised the partisan nature of its passage as a concern. The bill received no Republican votes in the House and only one in the Senate.
“It’s very worrisome for EPR if it becomes one party’s program,” Miller previously told Resource Recycling.
Upcoming assessments
In Washington, a Department of Ecology-led preliminary needs assessment is due by December 31, 2026, followed by a full needs assessment before CAA’s draft program plan is submitted by October 1, 2028. Full program implementation is expected January 1, 2030. Recycler reimbursements start at 50% and scale to 90% by 2032.
Maryland’s full Producer Responsibility Plan, which covers recycling, composting, reuse and waste reduction targets, is due to the state by July 1, 2028, the same date fee reimbursements to municipalities begin, rising to 75% in 2029 and 90% in 2030.
Maine was the first to pass a packaging EPR law in 2021. The Maine Board of Environmental Protection approved rules in December 2024, and stakeholder debates over the covered materials list continued into spring 2025.
An RFP to select a stewardship organization, which was originally planned for spring 2026, had not been issued as of early May. Maine DEP has said the RFP is coming soon, with producer registration and start-up fees still expected this year, but timing depends on when the department finalizes a contract.
CAA previously said it intends to apply.
Legal challenges
As July 1 deadlines approach in Washington and Maryland, packaging EPR framework in multiple states is facing legal pressure from organizations targeting CAA’s role as a private fee-setting entity.
In Oregon, a federal judge granted a narrow preliminary injunction in February blocking enforcement of SB 582 against members of the National Association of Wholesaler-Distributors, while dismissing the bulk of the broader challenge. A five-day trial is scheduled to begin July 13.
The injunction covers only NAW members who joined the organization prior to February 6, 2026. A similar challenge was filed in Colorado by the Independent Lubricant Manufacturers Association in March.
In California, the litigation regarding SB 54 continues to enter the ring. On June 2, Oceana, NRDC and Californians Against Waste Foundation sued CalRecycle in San Francisco Superior Court, arguing the finalized SB 54 regulations add exemptions that undermine the law’s core plastic reduction and recycling mandates.
“While SB 54 remains a monumental achievement as the nation’s strongest single-use plastic reduction law, some of the final regulations implementing the statute undermine the law’s ambitions,” said Christy Leavitt, Oceana’s senior campaign director, in a statement.
On June 22, NAW announced it is joining a 17-state coalition led by Nebraska Attorney General Mike Hilgers in a separate federal lawsuit challenging SB 54, alleging the law unconstitutionally delegates fee-setting authority to a private entity and restricts interstate commerce.
The group is seeking a preliminary injunction to block enforcement while the case proceeds, a similar argument that yielded the partial injunction in Oregon.
“No state should limit interstate commerce, let alone delegate the power to set and collect taxes to a third party outside of the scope of public scrutiny,” said Eric Hoplin, NAW president and CEO, in a statement.
