Independent US packaging EPR intelligence

California's EPR Registration Deadline Already Passed. Are You in the System?

Seven states have enacted packaging EPR laws. California goes fully live January 1, 2027. The first invoices land that month. This free tracker puts every deadline, PRO assignment, and published fee schedule on one page, updated quarterly.

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The cost of inaction

The cost of “wait and see”

The rules are moving from planning documents to invoices. These are the dates and figures already on the record.

01 — DEADLINE

You're possibly already late.

California's producer registration deadline was June 1, 2026. If you sell packaged goods in California and aren't registered with the Circular Action Alliance, the program launches January 1, 2027 whether you're ready or not.

02 — PENALTY

Up to $50,000 per day, per violation.

The penalty for being wrong is written into California law.

03 — MONEY

$167.9 million has already been collected.

Oregon's program was upheld by a federal court on August 27, 2026, and it collected that amount from nearly 3,000 participating producers in its initial months. CAA figures, reported by Waste Dive, July 2026.

04 — EXPOSURE

California's program budget is expected to exceed $9 billion.

That's over the next five years, according to Waste Dive reporting on CAA's draft program plan, June 2026. Your share gets calculated from packaging data you should be collecting now, not in December.

“EPR, because it was in the future, wasn't the thing on fire. It is now.”
Sara Lowe, Bay Cities Packaging & Design, quoted by Resource Recycling, June 2026. She estimated about half of her firm's clients made California's baseline reporting deadline; the other half are catching up now, without “the right people in the room.”

Litigation watch

The lawsuits won't save you

3live court challenges, including 17 state attorneys general suing California

But enforcement has not paused anywhere.

On August 27, 2026, a federal judge upheld Oregon's entire EPR program after a 5-day bench trial. It was the first full-record decision on US packaging EPR. That's now persuasive precedent against the California and Colorado challenges.

Waiting for the courts to rescue you is a bet. This tracker tells you exactly what that bet costs, quarter by quarter.

One clear working document

What's inside the tracker

01

All 7 enacted states: law, PRO, current status, and next deadline, all on one page.

02

The California timeline that matters: registration (passed June 1, 2026) → final fee schedule (October 13, 2026) → full launch and first invoices (January 2027).

03

Fee trajectories published so far. Every modeled estimate is clearly labeled as modeled, never presented as an official rate.

04

Why ~95 California material categories vs. ~60 in Colorado makes misclassification expensive. Market analysts are already flagging “rising penalties for incorrect classification.”

05

EU PPWR corner: live since August 12, 2026; first harmonized reporting June 2030.

06

Litigation watch: which challenges exist, where they stand, and what changed this quarter.

07

A “what to do this quarter” action checklist, in order of pain.

Covered states

7 states. One tracker.

California is the immediate deadline, not the whole map. The tracker follows every enacted US packaging EPR program from first fees through full operations.

01

Oregon

Fees have been collected since July 2025. In the program's initial months, nearly 3,000 producers paid a combined $167.9 million.

Fees collectingSince July 2025

02

Colorado

Fees have been collected since January 2026. The modeled average rises from $541 per ton in 2026 to $757 per ton in 2030.

Fees collectingSince Jan. 2026

03

California

The June 1, 2026 registration deadline has passed. The program goes live January 1, 2027, with first invoices that month. Penalties can reach $50,000 per day, per violation.

Registration passedLaunch Jan. 1, 2027

04

Maine

The program becomes operational in 2027, with first producer fee invoices expected that year.

ImplementationOperational 2027

05

Maryland

The enacted packaging EPR program is scheduled to become operational in 2028.

ImplementationOperational 2028

06

Minnesota

The enacted packaging EPR program is scheduled to become operational in 2029.

ImplementationOperational 2029

07

Washington

The enacted packaging EPR program is scheduled to become operational in 2030.

ImplementationOperational 2030

Fit check

Built for the team carrying the risk

This is for

Teams selling packaged goods in the US

Compliance, sustainability, finance, and procurement teams, and the consultants advising them. Especially mid-market brands that can't justify a $500 webinar or a law-firm engagement for every question.

This is not for

Companies outside the scope

Companies with no US packaged-goods sales. Or anyone looking for legal advice: this is an informational tracker, not a law firm. Talk to your counsel for compliance decisions.

How it stays current

As plans finalize, fees publish, and cases resolve

The tracker is updated every quarter as program plans finalize, fee schedules publish, and court cases resolve.

Subscribers get the new edition by email, plus the quarterly briefing. That's all we send. No drip sequences, no sales calls.

Free 2027 edition

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See the deadlines, PRO assignments, published fee schedules, and litigation status before the next California milestone.

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Who we are

Independent by design

EPR Monitor is an independent research desk tracking US packaging EPR (deadlines, PRO fee schedules, and litigation) across all 50 states and the EU.

We're not the PRO, not a law firm, and we don't sell packaging. We publish the tracker free; paid briefings and data products fund the work.

NOT THE PRONOT A LAW FIRMNO PACKAGING SALES