Staying Ahead of the Curve: A 2025 Update on U.S. Packaging EPR and Packaging Legislation

As packaging legislation rapidly evolves across the United States, brands are entering a new era of accountability. Extended Producer Responsibility (EPR) programs have now been implemented in six states and are being introduced in multiple others. Businesses must stay informed to meet the growing array of compliance mandates and renewed labeling requirements.

States With Active Packaging Legislation

Oregon: First U.S. EPR Reports Submitted, Fee Payment Due Soon

Oregon made headlines as the first U.S. state to activate its packaging EPR law under the Recycling Modernization Act (RMA). Over 1,700 producers submitted reports by the March 31, 2025 deadline, with many more during the grace period. The next key date? Fee payments due by July 1, 2025, based on final figures set for release by the Circular Action Alliance (CAA) in June.

Producers who failed to report may soon face enforcement action from Oregon’s Department of Environmental Quality (DEQ), which begins its compliance push in July.

Colorado: Reporting Deadline Approaching

Colorado’s EPR program is ramping up. By July 1, 2025, unregistered producers will be barred from selling in the state, and 2024 packaging data reports are due by July 31, 2025. If your team registered for Oregon through CAA, you’re already enrolled — but you still need to prepare your Colorado-specific sales data for submission.

California: EPR Rulemaking Resumes, Reporting Due in August

California’s landmark EPR law (SB 54) is back in motion after Governor Newsom restarted the rulemaking process in March 2025 to assure the law’s environmental goals are met and assure equality in their implementation. While timelines remain under review, the reporting deadline of August 31, 2025 for 2023 data is currently unchanged. Businesses operating in California should still plan on meeting 2025 deadlines, as states with active EPR programs have been staying true to their rollout timelines, even as programs adjust for reality. 

Key EPR Regulatory Changes to Watch

Several new states have passed or are finalizing EPR laws in 2025, adding to the regulatory patchwork brands must navigate:

• Maryland passed SB 901, becoming the sixth U.S. state with an EPR law. PRO cost-sharing phases in between 2028 and 2030.
  
  
• Minnesota named CAA as its PRO following the 2024 Packaging Waste Reduction Act. Initial registration is due by July 1, 2025, with full compliance timelines to follow.
  
  
• Washington passed SB 5284 in April 2025. If signed by the governor as expected, it will become the seventh state with packaging EPR, with full implementation by 2030.

These new laws reflect growing national momentum behind producer-funded recycling and accountability — and the urgent need for cross-functional data collection and compliance systems.

Recycling Law Updates: Labeling, PCR, and Bottle Bills

Changing packaging regulations in 2025 aren’t limited to EPR alone. Labeling, recycled content mandates, and deposit systems are also evolving rapidly. Several states are implementing recycling-related laws that affect packaging design and content.

California: Clearer Labels, Higher PCR Requirements

• SB 343 (Accurate Recycling Labels Law): Finalized in April 2025, this law bans the use of the ♻️ symbol and the term “compostable” on packaging that doesn't meet strict recyclability or compostability standards. Compliance deadlines are October 2026 (SB 343) and January 2026 (AB 1201).
  
  
• AB 793: Sets recycled content (PCR) requirements for plastic beverage containers — now at 25% PCR as of January 1, 2025, scaling to 50% by 2030.
  
  

New Jersey: PCR Reporting and Proposed EPR

• Recycled Content Law: Requires producers to meet escalating PCR targets across packaging materials. Reports are due to NJDEP by July 18, 2025.
  
  
• EPR Bill (S3398): Aims to reduce packaging by 25% and ensure full recyclability or compostability by 2034.
  
  

Expanding Bottle Bill Activity

• New York’s “Bigger Better Bottle Bill” would double deposit values and expand eligible containers.
  
  
• Hawaii and California are also considering deposit increases to boost recycling and reduce contamination.

These updates highlight the increasing importance of accurate packaging claims and design choices that align with recyclability standards.

Regulations in the Works: What’s Next?

Several states are actively exploring or preparing for packaging regulation reform:

• Connecticut is studying packaging EPR feasibility, with findings due by 2027.
  
  
• Tennessee’s Waste to Jobs Act proposes an ambitious EPR framework with economic and environmental goals — expected to resurface in 2026.
  
  
• Hawaii’s HB 1264 suggests a volume-based fee model for fast-moving consumer goods.
  
  
• Maine will require reporting and payments by 2026 under its finalized EPR program, and is revising recyclability criteria.

While some of these are early-stage proposals, they signal a shift toward broader packaging regulation across the U.S., especially as states seek to reduce waste, drive circularity, and hold producers accountable.

EPR is Here to Stay

From the Pacific Northwest to the Eastern Seaboard, packaging regulation is accelerating — and so are expectations for producer responsibility. What once seemed theoretical is now actionable: reporting deadlines, labeling rules, and PCR mandates are reshaping the packaging landscape.These legal developments are no longer limited to a few states with reputations for sustainability, they are becoming the standard.

As this regulatory web grows more complex, staying informed is not optional — it’s essential. At rePurpose Global, we’re committed to helping brands navigate these changes with confidence and clarity. From compliance toolkits to hands-on reporting support, our goal is to keep your team ahead of the curve. For an in-depth overview of packaging regulation updates and how your brand can prepare, connect with our team to receive our Packaging Compliance Bulletin. Now is the time to get your systems in place. The era of packaging responsibility is here — and it’s moving fast.