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Last Updated:

August 26, 2026. This guide is updated monthly with the latest EPR deadlines, fee schedules, and regulatory changes.

Key Deadlines, Fees, and Reporting Producers Should Prepare For

2025 marked a pivotal year for Extended Producer Responsibility (EPR) in the U.S., as multiple states enacted new laws shifting the responsibility for packaging waste to producers. In 2026, that momentum has continued. Producers can expect broader implementation across additional states, expanded reporting mandates, major compliance deadlines, and new fees. As EPR regulations evolve, rePurpose is here to help you stay informed, prepared, and compliant with the latest updates and a streamlined EPR compliance solution.

Key Updates Summary

• Six states shared a harmonized EPR reporting deadline this year: May 31, 2026. That date has passed — but if you're an obligated producer, your report is still due.
• CAA actively encourages non-reporting producers to submit their data even after a deadline has passed. Continuing to delay puts you at risk of non-compliance penalties.

• California:
  
  • The Producer Registration Portal is open, and late submissions for California reporting are still being accepted via the CAA portal. The initial deadline was Nov 15, 2025.
  • Producers finalized and submitted their 2023 baseline reports by June 1, 2026. This helps inform CAA's fee setting and source reduction planning. On August 20th, CAA announced that producers had until August 31 to make adjustments to their 2023 baseline data. While this is a short window to make changes, it came unexpectedly. Think of it as a grace period.
  • The Annual Supply Report and Annual Source Reduction Report using 2025 data were due May 31, 2026 (latest June 1).
  • The Individual Source Reduction (ISR) Plan was due August 3rd.
• Oregon and Colorado: 
  
  • Late EPR reporting for 2026 submissions is still being accepted. Just as with California, CAA's portal is designed to allow you to get in compliance even after deadlines have passed.
  • 2026 Producer invoices were issued in January.
  • Reporting portals opened March 31, and Annual Supply Reports using 2025 data were due May 31, 2026.
  • In Oregon, packaging producers may now make a claim for an exemption from paying fees in 2027 for the proportion of their products that are recycled privately through responsible end markets. The claims window was open from Jan. 7 through Mar. 31. Approval or denial of claims occurred by Jun 15.

• Washington, Minnesota, and Maryland:
  
  • The Producer Registration Portals remain open, though initial deadlines have passed.
  • Simplified Supply Reports were due May 31, 2026. Submit your reports now if you haven't already.
• Maine:
  
  • Maine's EPR timeline will be delayed. Maine's RFP for an SO/PRO did not get any bids, and CAA chose not to respond to the RFP.
  • Even without a deadline in place, obligated producers should get their data ready. Once the SO is selected, the clock for registration, reporting, and invoicing starts ticking.

Not sure which EPR states apply to you? Take our free 5-minute assessment to find out. 

Behind on reporting? We'll catch you up. Done faster, done right, done for you. Speak with our team to get it done.

2026 EPR Deadlines At A Glance

What’s New in 2026 EPR Compliance

After a year of fragmented timelines and state-by-state nuances, 2026 is the first year where Extended Producer Responsibility (EPR) obligations in the U.S. begin to harmonize. For producers selling into multiple states, this means clearer expectations, more aligned deadlines, and multiple sets of fees and reports due throughout the year.

Here’s a comprehensive look at what producers can expect in 2026 across Oregon, Colorado, California, and other emerging EPR states.

Harmonized EPR Reporting: May 31, 2026

Beginning in 2026, most states — led by Oregon, Colorado, and California — followed a consistent schedule:

• Annual Supply Reports Due: May 31, 2026
  
  • Annual Supply Report: detailed material data report across all defined categories
• Simplified Supply Reports Due: May 31, 2026
  
  • Simplified Supply Report: higher level report with fewer categories at the material class level (e.g. plastic, paper, glass)
• Producer Responsibility Fee Schedules Published: October 2026
• Invoices Issued: January and July (based on the prior year’s data) 2026

This marks a significant shift from 2025, where deadlines varied widely.

Oregon EPR: Full-Year Program Fees

Oregon, the earliest mover, began its EPR program in July 2025. Producers obligated in Oregon already submitted 2025 supply data on March 31, 2025 and paid fees in mid-2025.

In 2026:

• Producers pay full-year program fees based on their 2024 calendar-year supply data.
• Invoices were issued twice: January 2026 and July 2026.
• Reporting Portal opened March 31. The Portal is streamlined to resemble Colorado (with reduced questions).
• Updated guidance documents were released in March:
  
  • Producer and Covered Material Definitions
  • Ecomodulation Bonus A Guidance and Bonus A LCA Report Template
  • Ecomodulation Bonus B and Bonus C Guidance
  • LCA Bonus B&C Report Template
• 2 new reporting categories were added: 1) Other Paper Packaging - Molded Pulp Food Service Ware and 2) Plastic - Small Format - PE & PP Caps and Lids and HDPE Handles.
• Annual Supply Report and ecomodulation reports were due May 31, 2026 (using 2025 data).
• Non-compliance may result in penalties as high as $25,000/day. 

Compliance doesn’t have to be complex. rePurpose simplifies and streamlines the process with our automated compliance software. One setup and platform fee covers all current and future EPR states with the most up-to-date regulations. 

Colorado EPR: First Program Dues in 2026

Colorado required producers to determine obligation and submit 2024 supply data on July 31, 2025. This submission sets the baseline for Colorado’s 2026 program fees.

In 2026, Colorado’s first official program fee year:

• Producers pay program dues (fees) based on 2024 supply data submitted in July 2025.
• Invoices mirror Oregon’s schedule: January 2026 and July 2026.
• Noncompliance penalties include escalating daily fines:
  
  • The first violation is $5,000 for the first day and $1,500 for each following day.
  • The second violation is a $10,000 initial penalty and $3,000 per subsequent day. 
  • The third violation incurs an initial $20,000 fine and $6,000 for each following day.
• Reporting Portal opened on March 31.
• Mandatory PCR reporting is new to this year's supply report due May 31. This is different from the voluntary eco-modulation bonus. Producers must report the amount or % of PCR content in the packaging.
  
  
  • Evidence for PCR may be required, such as letters from converters or upstream suppliers, letters from reclaimers or contract manufacturers, third-party chain-of-custody certifications, procurement invoices, and transaction certificates.
• Reporting categories remain unchanged.
• Updated Producer Guidance and Covered Material Definitions were released on the producer portal.
• Colorado's Ecomodulation Guidance was also updated for 2026 reporting.
  
  • Reduction Bonus Template
  • Enhancement Bonus Template
  • PCR Content Bonus Template
  • Reuse/Refill Bonus Template‍

In addition to fines, non-compliance can lead to the restriction of selling products in the state.

California EPR: Early Fees and Source Reduction Plans

California’s EPR program (SB 54) remains the most complex and 2026 is the year it formally ramps up.

Early Fees in 2026

Producers:

• Submitted material data supply reports by May 31, 2026 (for 2025 data).
• Paid one-time early-fees based on invoices issued in August 2026. These early fees fund California’s pre-program activities ahead of the full 2027 program launch.

Final Regulations and Additional Reporting

California’s regulations will be finalized during 2026. Producers were required to:

• Submit a final 2023 data baseline report by May 31 (latest June 1, since May 31 fell on a Sunday). This is the baseline for your source reduction plan.

Additionally:

• Producers submitted an Annual Producer Supply Report using 2025 data by June 1.
• Producers submitted an Annual Source Reduction Report using 2025 data by June 1 in addition to the Supply Report.
  
  • The Annual Source Reduction Report only covers plastic and the producer's actual source reduction efforts and outcomes.
• Additional guidance, along with the bonus and malus schedule, was released by May 1st.
• Producers submitted an Individualized Source Reduction (ISR) Plan by August 1, guided by state-defined reduction targets. The ISR Plan Portal opened on June 1st. CAA has published detailed guidance and a reporting workbook.

Together, these steps set the foundation for California's formal program activation in 2027. For a more comprehensive guide on California EPR reporting, check out these resources:

• CA EPR Compliance: Step-by-Step Guide
• CA Source Reduction Compliance Checklist
• CA Source Reduction Mandates
• CA Reporting Requirements

CalRecycle's updated guidance includes a flowchart to understanding producer responsibility, a covered materials guidance, guidance for exclusions, and source reduction reporting guidance.

If these evolving regulations and tracking dozens of documents feel overwhelming, our team is here to help. Book a call with us to see how rePurpose simplifies this reporting process and supports source reduction planning.

Maryland, Minnesota, and Washington EPR: Startup Fees Coming

Maryland, Minnesota, and Washington all remain open for registration in the CAA portal. In 2026, each of these states require:

• A Simplified Supply Report due May 31, 2026 using 2025 supply data.
• Minnesota's producer portal opened up for reporting.
• Maryland and Washington producer portals opened for reporting in late April.

Maine EPR: Timeline Delayed Without A Stewardship Organization

Maine’s EPR program continues developing, but unlike the other states, a stewardship organization (SO/PRO) has not yet been selected. As of August 26, 2026, the big news coming out of Maine is that there were no bids on their RFP for an SO. CAA was the presumed frontrunner to be selected, but they chose not to respond to the RFP due to misalignment. Read more in detail about this announcement here.

EPR laws are still active in Maine, but the implementation timelines will be delayed until an SO is selected. Previously published targets of registration and invoicing (by end of 2026) are not likely to happen on that time frame. Producers have no Maine registration, reporting, or fee obligation until an SO is under contract. The 90-day registration clock only begins when a contracted SO opens registration.

Maine's struggle to secure a new SO/PRO could add more fragmentation in reporting deadlines and requirements that's hard to keep up with. Whatever the outcome, we're here with the updates and support to help you navigate this evolving regulation. But regardless of timeline, one thing doesn't change: data readiness. It's consistently the hardest part of the reporting process — and it's exactly where the rePurpose platform delivers.

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De Minimis Producers (Small Business Exemptions)

In several states, "de minimis" is the official legal term used to describe a small producer that is exempt from EPR program obligations because their environmental footprint or revenue is deemed insignificant.

If your business falls under the state's revenue limit OR supplies less than the state's minimum tonnage, you are exempt.

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Summary: 2026 EPR Compliance Checklist: What You Need to Do

Multiple fees across multiple states
— Oregon: two invoices (Jan & July)
— Colorado: two invoices (Jan & July)
— California: one early-fee invoice (Aug)

Different types of reporting

— 2025 Annual Supply Report and Simplified Supply Report( May 31)
— California Final 2023 Baseline Report (May 31, with a short window to adjust numbers until August 31)
— California Annual Source Reduction Report (May 31)
— California Individual Source Reduction Plan using 2023 baseline data (August 3)

CAA Portal Updates for Reporting

• Reporting Portals remain open for all EPR state reports.
• To make edits to reports before the submission due date, make a resubmission request via the Help and Support Tab. After the submission date passes, formal adjustments must be filed.
• Supply data gets pulled into annual source reduction reports without lag time. As soon as the producer completes and submits the California baseline report and annual supply report, that data gets auto-populated into the annual source reduction report.
• CAA emphasizes that the methodology section is critical. Producers should explain data sources, assumptions, estimation methods, deductions, exclusions, and internal validation steps as fully as possible. A strong methodology statement can reduce the risk of later correction issues or inaccurate-reporting charges.
• CAA has published a Producer Delinquency Policy that outlines how CAA identifies and works with producers to resolve unfulfilled producer obligations.

Preparing for Multi-State EPR in 2027

2026 is the most operationally intensive year for producers navigating EPR. With multiple reports, fee cycles, and regulatory updates converging, producers who prepare early and centralize their compliance processes will be positioned for a much smoother transition into 2027.

Streamline Your 2026 EPR Compliance with rePurpose 

The rePurpose packaging compliance platform centralizes supply data, harmonizes reporting formats across states, and keeps producers ahead of every deadline, from May 31st submissions to August early fees and January/July invoices.

Whether you're managing reporting for one state or all six emerging EPR programs, rePurpose helps ensure accuracy, reduce manual effort, and streamline compliance as regulations rapidly evolve. Book a demo with our team.

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