Maine received no proposals for the contract to administer its packaging EPR program, the state Department of Environmental Protection (DEP) said on August 20.
This setback leaves the country’s first statewide packaging stewardship law without a path to implementation.
The state’s request for proposals (RFP) closed August 18 with no submissions. DEP said it is “assessing all options” and will share more in a future newsletter. The department did not specify what those options include.
The result follows a decision this week by producer responsibility organization (PRO) Circular Action Alliance (CAA) not to bid.
CAA cited a lack of alignment between the RFP’s scope and the organization’s “operational practices, systems and data stewardship standards” as the reason, while stopping short of ruling out a future solicitation.
CAA is the sole PRO implementing packaging EPR groundwork for California, Colorado, Maryland, Minnesota, Oregon and Washington, leaving Maine as the only state with an enacted packaging EPR law and no organization in place.
Maine framework differs from other states
The outcome tracks with a structural gap that has followed the program for years. Maine’s cost-reimbursement model, in which producers directly fund municipal recycling costs, splits from the “shared responsibility” framework California, Colorado, Maryland, Minnesota, Oregon and Washington have adopted. A bidder would need to implement a bespoke framework rather than extend infrastructure built for other states.
Cost concerns have also shadowed the program since rulemaking. The Maine State Chamber of Commerce objected to the inclusion of disposal costs in reimbursement rates during the 2024 final-rules process, and lawmakers passed industry-backed amendments in 2025 partly to ease compliance costs.
Maine remains the only state with an enacted packaging EPR law that has yet to contract a stewardship organization. The program has been stalled at step four of DEP’s nine-step implementation process, contracting a stewardship organization, since December 2024, when the state adopted final program rules.
DEP had anticipated beginning registration and invoicing by the end of 2026, with municipal reimbursements starting in late 2027. Those projections assumed a contract would be signed following this RFP cycle.
Enacted in 2021, Maine’s law was the first in the nation to require producers to fund packaging recycling costs for municipalities, though it uses a cost-reimbursement model distinct from the PRO structure adopted by other states.
With no stewardship organization under contract, producers currently have no registration, reporting or fee obligations under the law.
