# California extended producer responsibility

Last verified: November 5, 2026 · https://instica.com/epr/california

<a id="answer"></a>

California requires producers who place packaging on the market to meet packaging EPR duties under California SB 54, Plastic Pollution Prevention and Packaging Producer Responsibility Act. The regulator is CalRecycle (Department of Resources Recycling and Recovery), through its PEPRS portal. We record 1 threshold and 3 dated deadlines.

<a id="overview"></a>

## Packaging EPR in California: what we have verified

This page collects what we have verified about packaging extended producer responsibility (EPR) in California. 12 of 16 core rule fields are published from primary sources and 4 are not yet published. The dataset was last reviewed on September 29, 2026, and the newest source on this page was retrieved on November 3, 2026.

- **Regime**: [California SB 54, Plastic Pollution Prevention and Packaging Producer Responsibility Act (Public Resources Code, Division 30, Part 3, Chapter 3.1)](#regime)
- **Regulator**: [CalRecycle (Department of Resources Recycling and Recovery), through its PEPRS portal](#regulator)
- **Producers obliged**: [Yes](#obligated)
- **System**: [a single producer responsibility organisation](#organisation)
- **Registration**: [Required](#registration)
- **Fee schedules**: 1

<a id="regime"></a>The packaging EPR regime in California is recorded as California SB 54, Plastic Pollution Prevention and Packaging Producer Responsibility Act (Public Resources Code, Division 30, Part 3, Chapter 3.1).

<a id="regulator"></a>The regulator named for California is CalRecycle (Department of Resources Recycling and Recovery), through its PEPRS portal.

<a id="obligated"></a>Producers placing packaging on the market in California carry a packaging EPR obligation.

> SB 54 establishes a new extended producer responsibility (EPR) program to manage packaging and single-use plastic food service ware products
>
> Source: Regime (https://calrecycle.ca.gov/packaging/packaging-epr/), Retrieved: September 29, 2026, Language: en

> **Not yet published**: Not yet published for California: treatment of affiliates, the material categories, labelling, and filing languages. Each of these stays blank until a primary source is verified; we do not fill gaps from memory or from other jurisdictions.

<a id="who"></a>

## Who is the producer in California

In California, packaging EPR obliges producers to organise or fund the collection and recycling of the packaging they place on the market. The sections below set out who counts as the producer, which thresholds decide whether a business is in scope, and what has to be filed.

The producer hierarchy decides who answers for a pack when several businesses touch it. For California, the dataset names the following roles for each packaging level.

<a id="producer-hierarchy"></a>**Who is the producer in California, by packaging level**

| Packaging level | Producer roles recorded |
| --- | --- |
| other packaging | manufacturer or brand owner, licensee, first distributor |
| primary (sales) packaging | manufacturer or brand owner, licensee, first distributor |
| secondary packaging | manufacturer or brand owner, licensee, first distributor |
| service packaging | manufacturer or brand owner, licensee, first distributor |
| shipping packaging | manufacturer or brand owner, licensee, first distributor |
| tertiary (transport) packaging | manufacturer or brand owner, licensee, first distributor |

<a id="producer-default"></a>In California, the party that carries the obligation by default is the manufacturer or brand owner, licensee, and first distributor.

> the producer of the covered material is the person who sells, offers for sale, or distributes the product that uses the covered material
>
> Source: Producer hierarchy (https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=PRC&sectionNum=42041), Retrieved: September 29, 2026, Language: en

<a id="transfer"></a>In California, the obligation cannot be transferred to another party.

Transfer detail: none found in PRC 42041(w); third-party sellers on an online marketplace are the retailer, not the marketplace operator, PRC 42041(ae)(2)

<a id="affiliates"></a>Whether affiliates are counted together in California: not yet published. Reason: The CalRecycle page does not say whether affiliate sales aggregate toward the $1 million limit. The definition sits in 14 CCR 18980.5.2, which was not read verbatim.

<a id="revenue-scope"></a>Where a revenue test applies in California, it is measured on revenue earned in the jurisdiction over calendar year, in USD.

Roles matter because an online seller, an importer and a brand owner can each be the producer for the same pack, and a pack is counted once. If you sell into California through a marketplace, check whether the marketplace or you are recorded as the obligated party. Confirm who is responsible for reporting.

<a id="thresholds"></a>

## Thresholds that apply in California

Thresholds decide whether a business is in scope, whether it pays fees, or whether it can file a simplified report. California publishes 1 verified threshold.

<a id="thresholds-table"></a>**Thresholds recorded for California**

| Measure | Amount | Effect | Note |
| --- | --- | --- | --- |
| [revenue](#threshold-small_producer_gross_annual_sales) | below $1,000,000.00 | the producer is exempt below it |  |

<a id="threshold-small_producer_gross_annual_sales"></a>California sets a revenue threshold of below $1,000,000.00; effect: the producer is exempt below it.

Basis of the revenue threshold: gross annual sales in California, most recent calendar year.

> Small producers with gross annual sales of less than $1 million may apply to be exempt from most of the law’s reporting and fee requirements.
>
> Source: Threshold (https://calrecycle.ca.gov/packaging/packaging-epr/exemptionsexclusions/), Retrieved: September 29, 2026, Language: en

<a id="exemptions"></a>

## Exemptions in California

An exemption removes or reduces a duty for a defined group. California lists 4 exemptions in the dataset. Some apply automatically; others only apply if you ask the regulator for them, usually within a window.

<a id="exemption-small_producer"></a>Exemption in California: Temporary, renewable exemption from most reporting and fee requirements for producers with gross annual California sales under $1 million. Long-term duty remains: all packaging recyclable or compostable by 2032. You must apply for it.

Application window: Register in PEPRS as a Packaging EPR producer, then file the small producer exemption application.

> To apply, first register in CalRecycle’s reporting system, known as PEPRS, as a Packaging EPR producer. Then fill out the small producer exemption application.
>
> Source: Exemption (https://calrecycle.ca.gov/packaging/packaging-epr/exemptionsexclusions/), Retrieved: September 29, 2026, Language: en

<a id="exemption-agricultural_commodity_on_site"></a>Exemption in California: A person who produces, harvests and packages an agricultural commodity on the site where it was grown or raised is not a producer. It applies without a separate application.

> “Producer” does not include a person who produces, harvests, and packages an agricultural commodity on the site where the agricultural commodity was grown or raised.
>
> Source: Exemption (https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=PRC&sectionNum=42041), Retrieved: September 29, 2026, Language: en

<a id="exemption-crv_beverage_containers"></a>Exemption in California: Beverage containers subject to the California Beverage Container Recycling and Litter Reduction Act are not covered material. It applies without a separate application.

> Beverage containers subject to the California Beverage Container Recycling and Litter Reduction Act (Division 12.1 (commencing with Section 14500)).
>
> Source: Exemption (https://www2.calrecycle.ca.gov/Docs/Web/131538), Retrieved: September 29, 2026, Language: en

<a id="exemption-high_recycling_rate_material"></a>Exemption in California: Covered material meeting a 65% (through 2026) or 70% (2027 on) recycling rate, outside curbside collection and commingled sorting, recycled at responsible end markets, is not covered material once CalRecycle approves the producer's demonstration. You must apply for it.

Application window: annual demonstration to CalRecycle until 2027, every two years after

> Achieve 65% recycling rates from 2024 to 2026, and 70% in 2027 and after
>
> Source: Exemption (https://calrecycle.ca.gov/packaging/packaging-epr/exemptionsexclusions/), Retrieved: September 29, 2026, Language: en

<a id="registration-system"></a>

## Registration and the system in California

Registration is where an obligation becomes visible to the regulator. The records below show whether California asks producers to register, with whom, and which organisation or scheme carries the collection and recycling system.

<a id="registration"></a>Producers in California must register with PEPRS (CalRecycle Packaging Extended Producer Responsibility System).

Who registers: The producer, or Circular Action Alliance on behalf of participants

[Registry](https://secure.calrecycle.ca.gov/PEPRS/) (opens the official registry page).

> Circular Action Alliance manages registration, reporting, and submissions of certain exemptions and exclusions on the producers’ behalf.
>
> Source: Registration (https://calrecycle.ca.gov/packaging/packaging-epr/producerguidance/), Retrieved: September 29, 2026, Language: en

<a id="organisation"></a>In California, the system runs through a single producer responsibility organisation: Circular Action Alliance; membership is required.

> Circular Action Alliance has been approved to serve as the first Producer Responsibility Organization.
>
> Source: Organisation (https://calrecycle.ca.gov/packaging/packaging-epr/), Retrieved: September 29, 2026, Language: en

<a id="categories"></a>The material categories in California: not yet published. Reason: The exact CMC count and machine-readable list were not confirmed. Count 89 is distinct 25_ tokens extracted from the guidance PDF text and includes truncated ids; a taxonomy file must be built from the CalRecycle CMC list page.

<a id="deadlines"></a>

## Deadlines in California

California records 4 deadlines, 3 of them verified. This page gives the summary; every date, the period it covers and what it requires are on the deadlines page for California.

The next dated obligation we hold for California falls on January 1, 2027. 1 more dated obligation follows it.

See every deadline for California, with its period and what it requires, on the [California deadlines page](https://instica.com/epr/california/deadlines).

A deadline is a date the regulator published, not a date we set. We can estimate what you may owe and prepare the report file; you sign and submit it in the regulator's own portal.

<a id="fees-reporting"></a>

## Fees and reporting in California

California publishes 1 fee schedule, for fee year 2026. The schedule sets what each kind of packaging costs; the rates themselves are on the fee pages, not here.

The 2026 schedule is based on packaging placed on the market from January 1, 2025 to December 31, 2025.

- California 2026 fees: rates by material for fee year 2026.

The report you file is a defined file or form. California records 1 format; we prepare the file to that specification and you upload it yourself.

California SB 54 producer data by covered material category is a csv file submitted through CAA producer portal, or CalRecycle PEPRS when the producer reports directly. The customer signs in and submits. The customer reviews, signs and submits it.

Columns, material mapping and the checks a file must pass are on the California report format page.

<a id="obligations"></a>

## Labelling, languages, targets and penalties in California

<a id="labelling"></a>Labelling in California: not yet published. Reason: No producer labelling rule was found in the sources read. Confirm against 14 CCR Article 6 before relying on required=false.

<a id="languages"></a>Languages in California: not yet published. Reason: No page states a filing-language rule. English is recorded because the portal and forms are English only; confirm with CalRecycle.

<a id="target-source_reduction_2027"></a>California sets a target for plastic source reduction: 10 by January 1, 2027.

<a id="target-source_reduction_2030"></a>California sets a target for plastic source reduction: 20 by January 1, 2030.

<a id="target-source_reduction_2032"></a>California sets a target for plastic source reduction: 25 by January 1, 2032.

<a id="target-plastic_recycling_2028"></a>California sets a target for plastic recycling rate: 30 percent by January 1, 2028.

<a id="target-plastic_recycling_2030"></a>California sets a target for plastic recycling rate: 40 percent by January 1, 2030.

<a id="target-plastic_recycling_2032"></a>California sets a target for plastic recycling rate: 65 percent by January 1, 2032.

<a id="target-recyclable_or_compostable_2032"></a>California sets a target for recyclable or compostable share: 100 percent by January 1, 2032.

<a id="penalty-1"></a>California sets a penalty for failure to comply with the chapter or its regulations: up to $50,000 per day per violation. Escalation: reduced to 25000 for entities meeting PRC 42060(a)(5); accrues from 30 days after notice of violation.

Labelling, language, target and penalty rules are the parts of a regime that are easiest to miss. A report filed in the wrong language or a pack without a required mark can cost as much as a late payment, so read each of these against your own products.

<a id="compare"></a>

## California compared with nearby places

Rules do not stop at a border. A business that sells into California usually sells into its neighbours too, and the thresholds and deadlines differ. The table reads California against the places closest to it that have verified data.

<a id="neighbours"></a>**California read against neighbouring and similar places**

| Place | Producers obliged | Regulator | Registration |
| --- | --- | --- | --- |
| [Oregon](https://instica.com/epr/oregon) | [Yes](#cmp-US-OR-obligated) | [Oregon Department of Environmental Quality (DEQ)](#cmp-US-OR-regulator) | Required |
| [Colorado](https://instica.com/epr/colorado) | [Yes](#cmp-US-CO-obligated) | [Colorado Department of Public Health and Environment (CDPHE), Solid Waste and Materials Management Program](#cmp-US-CO-regulator) | Required |
| [Washington](https://instica.com/epr/washington) | [Yes](#cmp-US-WA-obligated) | [Washington State Department of Ecology](#cmp-US-WA-regulator) | Required |
| [Maine](https://instica.com/epr/maine) | [Yes](#cmp-US-ME-obligated) | [Maine Department of Environmental Protection](#cmp-US-ME-regulator) | Required |
| [Minnesota](https://instica.com/epr/minnesota) | [Yes](#cmp-US-MN-obligated) | [Minnesota Pollution Control Agency](#cmp-US-MN-regulator) | Required |
| [Maryland](https://instica.com/epr/maryland) | [Yes](#cmp-US-MD-obligated) | [Maryland Department of the Environment](#cmp-US-MD-regulator) | Required |
| [United Kingdom](https://instica.com/epr/uk) | [Yes](#cmp-GB-obligated) | [Four environmental regulators (Environment Agency, Natural Resources Wales, SEPA, NIEA); PackUK is the scheme administrator that sets fees](#cmp-GB-regulator) | Required |
| [Belgium](https://instica.com/epr/belgium) | [Yes](#cmp-BE-obligated) | [Interregional Packaging Commission (IVC-CIE, now EPRiBEL)](#cmp-BE-regulator) | Required |

<a id="compare-records"></a>

## Records behind the comparison

<a id="cmp-US-OR-regime"></a>The regime in Oregon is recorded as Oregon Recycling Modernization Act, ORS 459A.860 to 459A.975 (SB 582 of 2021).

<a id="cmp-US-OR-organisation"></a>Oregon runs its system through a single producer responsibility organisation: Circular Action Alliance.

<a id="cmp-US-OR-threshold"></a>Oregon sets a revenue threshold of below $5,000,000.00.

<a id="cmp-US-OR-deadline"></a>Oregon has a reporting deadline on May 31, 2026.

<a id="cmp-US-CO-regime"></a>The regime in Colorado is recorded as Colorado Producer Responsibility Program for Statewide Recycling Act, C.R.S. 25-17-701 et seq. (HB22-1355).

<a id="cmp-US-CO-organisation"></a>Colorado runs its system through more than one producer responsibility organisation: Circular Action Alliance and Interchange 360 (automotive lubricant packaging, individual programme).

<a id="cmp-US-CO-threshold"></a>Colorado sets a revenue threshold of below $5,000,000.00.

<a id="cmp-US-CO-deadline"></a>Colorado has a payment deadline on January 1, 2026.

<a id="cmp-US-WA-regime"></a>The regime in Washington is recorded as Washington Recycling Reform Act, chapter 70A.208 RCW.

<a id="cmp-US-WA-organisation"></a>Washington runs its system through a single producer responsibility organisation: Circular Action Alliance.

<a id="cmp-US-WA-threshold"></a>Washington sets a tonnage threshold of below 1 short ton.

<a id="cmp-US-WA-deadline"></a>Washington has a deadline of another kind on March 1, 2026.

<a id="cmp-US-ME-regime"></a>The regime in Maine is recorded as Maine Stewardship Program for Packaging, 38 M.R.S. section 2146.

<a id="cmp-US-ME-organisation"></a>Maine runs its system through a single producer responsibility organisation.

<a id="cmp-US-ME-threshold"></a>Maine sets a revenue threshold of below $2,000,000.00.

<a id="cmp-US-ME-deadline"></a>Maine has a reporting deadline on May 31, 2027.

<a id="cmp-US-MN-regime"></a>The regime in Minnesota is recorded as Minnesota packaging EPR law, Minnesota Statutes sections 115A.144 to 115A.1463.

<a id="cmp-US-MN-organisation"></a>Minnesota runs its system through a single producer responsibility organisation: Circular Action Alliance.

<a id="cmp-US-MN-threshold"></a>Minnesota sets a tonnage threshold of below 1 short ton.

<a id="cmp-US-MN-deadline"></a>Minnesota has a registration deadline on July 1, 2026.

<a id="cmp-US-MD-regime"></a>The regime in Maryland is recorded as Maryland packaging and paper products producer responsibility law (SB 901, 2025).

<a id="cmp-US-MD-organisation"></a>Maryland runs its system through a single producer responsibility organisation: Circular Action Alliance.

<a id="cmp-US-MD-threshold"></a>Maryland sets a tonnage threshold of below 1 short ton.

<a id="cmp-US-MD-deadline"></a>Maryland has a registration deadline on May 31, 2026.

<a id="cmp-GB-regime"></a>The regime in United Kingdom is recorded as Extended producer responsibility (EPR) for packaging, under the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024.

<a id="cmp-GB-organisation"></a>United Kingdom runs its system through registered schemes that producers join.

<a id="cmp-GB-threshold"></a>United Kingdom sets a tonnage threshold of above 25 tonnes.

<a id="cmp-GB-deadline"></a>United Kingdom has a reporting deadline on October 1, 2026.

<a id="cmp-BE-regime"></a>The regime in Belgium is recorded as Belgian interregional Cooperation Agreement on packaging waste, in force in its current version since 5 March 2020; enforced by the Interregional Packaging Commission (IRPC/IVC-CIE).

<a id="cmp-BE-organisation"></a>Belgium runs its system through more than one producer responsibility organisation: Fost Plus (household) and Valipac (industrial).

<a id="cmp-BE-threshold"></a>Belgium sets a tonnage threshold of 300 tonnes of single-use packaging per year.

<a id="cmp-BE-deadline"></a>Belgium has a deadline of another kind on September 15, 2026.

<a id="pairs"></a>

## California read against each neighbour

Each paragraph reads California against one place from the table above, using only records verified for both. A part is left out when either side is not yet published.

California and [Oregon](#cmp-US-OR-obligated) both record an obligation for packaging producers. The regulator is CalRecycle (Department of Resources Recycling and Recovery), through its PEPRS portal in California and [Oregon Department of Environmental Quality (DEQ)](#cmp-US-OR-regulator) next door. Both run a single producer responsibility organisation. Registration is required in both. The first threshold is $1,000,000.00 of revenue in California against [$5,000,000.00 of revenue](#cmp-US-OR-threshold) in Oregon, so a seller can be in scope here and below the line next door. The earliest recorded deadline is January 1, 2027 in California and [July 1, 2025](#cmp-US-OR-deadline) in Oregon, 549 days later here.

California and [Colorado](#cmp-US-CO-obligated) both record an obligation for packaging producers. The regulator is CalRecycle (Department of Resources Recycling and Recovery), through its PEPRS portal in California and [Colorado Department of Public Health and Environment (CDPHE), Solid Waste and Materials Management Program](#cmp-US-CO-regulator) next door. California runs a single producer responsibility organisation, while Colorado runs [more than one producer responsibility organisation](#cmp-US-CO-organisation). Registration is required in both. The first threshold is $1,000,000.00 of revenue in California against [$5,000,000.00 of revenue](#cmp-US-CO-threshold) in Colorado, so a seller can be in scope here and below the line next door. The earliest recorded deadline is January 1, 2027 in California and [January 1, 2026](#cmp-US-CO-deadline) in Colorado, 365 days later here.

California and [Washington](#cmp-US-WA-obligated) both record an obligation for packaging producers. The regulator is CalRecycle (Department of Resources Recycling and Recovery), through its PEPRS portal in California and [Washington State Department of Ecology](#cmp-US-WA-regulator) next door. Both run a single producer responsibility organisation. Registration is required in both. The first thresholds are measured differently: $1,000,000.00 of revenue in California and [1 short ton of tonnage](#cmp-US-WA-threshold) in Washington, so the figures cannot be compared directly. The earliest recorded deadline is January 1, 2027 in California and [March 1, 2026](#cmp-US-WA-deadline) in Washington, 306 days later here.

California and [Maine](#cmp-US-ME-obligated) both record an obligation for packaging producers. The regulator is CalRecycle (Department of Resources Recycling and Recovery), through its PEPRS portal in California and [Maine Department of Environmental Protection](#cmp-US-ME-regulator) next door. Both run a single producer responsibility organisation. Registration is required in both. The first threshold is $1,000,000.00 of revenue in California against [$2,000,000.00 of revenue](#cmp-US-ME-threshold) in Maine, so a seller can be in scope here and below the line next door. The earliest recorded deadline is January 1, 2027 in California and [May 31, 2027](#cmp-US-ME-deadline) in Maine, 150 days earlier here.

California and [Minnesota](#cmp-US-MN-obligated) both record an obligation for packaging producers. The regulator is CalRecycle (Department of Resources Recycling and Recovery), through its PEPRS portal in California and [Minnesota Pollution Control Agency](#cmp-US-MN-regulator) next door. Both run a single producer responsibility organisation. Registration is required in both. The first thresholds are measured differently: $1,000,000.00 of revenue in California and [1 short ton of tonnage](#cmp-US-MN-threshold) in Minnesota, so the figures cannot be compared directly. The earliest recorded deadline is January 1, 2027 in California and [May 31, 2026](#cmp-US-MN-deadline) in Minnesota, 215 days later here.

California and [Maryland](#cmp-US-MD-obligated) both record an obligation for packaging producers. The regulator is CalRecycle (Department of Resources Recycling and Recovery), through its PEPRS portal in California and [Maryland Department of the Environment](#cmp-US-MD-regulator) next door. Both run a single producer responsibility organisation. Registration is required in both. The first thresholds are measured differently: $1,000,000.00 of revenue in California and [1 short ton of tonnage](#cmp-US-MD-threshold) in Maryland, so the figures cannot be compared directly. The earliest recorded deadline is January 1, 2027 in California and [May 31, 2026](#cmp-US-MD-deadline) in Maryland, 215 days later here.

California and [United Kingdom](#cmp-GB-obligated) both record an obligation for packaging producers. The regulator is CalRecycle (Department of Resources Recycling and Recovery), through its PEPRS portal in California and [Four environmental regulators (Environment Agency, Natural Resources Wales, SEPA, NIEA); PackUK is the scheme administrator that sets fees](#cmp-GB-regulator) next door. California runs a single producer responsibility organisation, while United Kingdom runs [registered schemes that producers join](#cmp-GB-organisation). Registration is required in both. The first thresholds are measured differently: $1,000,000.00 of revenue in California and [25 tonnes of tonnage](#cmp-GB-threshold) in United Kingdom, so the figures cannot be compared directly. The earliest recorded deadline is January 1, 2027 in California and [October 1, 2026](#cmp-GB-deadline) in United Kingdom, 92 days later here.

California and [Belgium](#cmp-BE-obligated) both record an obligation for packaging producers. The regulator is CalRecycle (Department of Resources Recycling and Recovery), through its PEPRS portal in California and [Interregional Packaging Commission (IVC-CIE, now EPRiBEL)](#cmp-BE-regulator) next door. California runs a single producer responsibility organisation, while Belgium runs [more than one producer responsibility organisation](#cmp-BE-organisation). Registration is required in both. The first thresholds are measured differently: $1,000,000.00 of revenue in California and [300 tonnes of single-use packaging per year of tonnage](#cmp-BE-threshold) in Belgium, so the figures cannot be compared directly. The earliest recorded deadline is January 1, 2027 in California and [August 12, 2026](#cmp-BE-deadline) in Belgium, 142 days later here.

<a id="position"></a>

## Where California sits among the places we cover

Counted by verified core records, California holds 12 of 17 and ranks 7 of 53 places in the dataset. The places just ahead of it are United Kingdom Plastic Packaging Tax (14), [United Kingdom](https://instica.com/epr/uk) (13), [Oregon](https://instica.com/epr/oregon) (13), [Belgium](https://instica.com/epr/belgium) (12), Ontario (12) and [Italy](https://instica.com/epr/italy) (12). The places just behind it are [Austria](https://instica.com/epr/austria) (11), [British Columbia](https://instica.com/epr/british-columbia) (11), [Switzerland](https://instica.com/epr/switzerland) (11), [Colorado](https://instica.com/epr/colorado) (11), [Bulgaria](https://instica.com/epr/bulgaria) (10) and [New Brunswick](https://instica.com/epr/new-brunswick) (10).

Counting every verified record, not only the core fields, California holds 20 and ranks 10 of 53. Ahead of it are [United Kingdom](https://instica.com/epr/uk) (24), United Kingdom Plastic Packaging Tax (24), [Belgium](https://instica.com/epr/belgium) (22), [Washington](https://instica.com/epr/washington) (22), [Québec](https://instica.com/epr/quebec) (21) and [British Columbia](https://instica.com/epr/british-columbia) (20). Behind it are [Minnesota](https://instica.com/epr/minnesota) (19), [Germany](https://instica.com/epr/germany) (18), [Maryland](https://instica.com/epr/maryland) (18), [Bulgaria](https://instica.com/epr/bulgaria) (17), Czechia (17) and [Denmark](https://instica.com/epr/denmark) (17).

All 7 places in this region in the dataset record an obligation, so California is not an outlier among its neighbours.

Ordered by earliest verified deadline, California comes 39 of 41, on January 1, 2027. Before it come [Sweden](https://instica.com/epr/sweden) (August 12, 2026, 142 days earlier), Slovenia (August 12, 2026, 142 days earlier), Slovakia (August 12, 2026, 142 days earlier), [Alberta](https://instica.com/epr/alberta) (October 1, 2026, 92 days earlier), [United Kingdom](https://instica.com/epr/uk) (October 1, 2026, 92 days earlier) and [Germany](https://instica.com/epr/germany) (December 31, 2026, 1 day earlier). After it come United Kingdom Plastic Packaging Tax (April 1, 2027, 90 days later) and [Maine](https://instica.com/epr/maine) (May 31, 2027, 150 days later).

Among places whose first threshold is also counted in revenue, California sits 1 of 4 from the lowest. The table sets it beside the places just below and just above.

<a id="threshold-ladder"></a>**First thresholds near California, lowest first**

| Place | First threshold | Against this page |
| --- | --- | --- |
| [California](https://instica.com/epr/california) | $1,000,000.00 | This page |
| [Maine](https://instica.com/epr/maine) | $2,000,000.00 | Higher |
| [Colorado](https://instica.com/epr/colorado) | $5,000,000.00 | Higher |
| [Oregon](https://instica.com/epr/oregon) | $5,000,000.00 | Higher |

<a id="prepare"></a>

## What to prepare for California

1. Work out whether you are the producer for each product you sell in California, using the producer roles above.
2. Compare your California revenue and packaging weight with each threshold in the table; keep the working.
3. Register with PEPRS (CalRecycle Packaging Extended Producer Responsibility System) before you report or pay.
4. Put every dated deadline above in your calendar, with the period it covers.
5. Collect packaging weights by material so the report file can be prepared to the format above.
6. Sign and submit your filings yourself in the regulator's portal; Instica never stores portal credentials and never files for you.

Instica measures packaging, estimates what you may owe and prepares the report file. It does not decide whether you are obliged; that stays with you and the regulator.

<a id="method"></a>

## How to read this page

Every statement on this page is generated from a verified record, and each record keeps its source address, the date we retrieved it, and, where the source is a statute or notice, the quoted text. A value marked "not yet published" has no verified source yet; we show the reason instead of a number.

Quotes are shown in the language of the source with a labelled summary in English. The summary helps you read; the quote is what the source says. If the two ever differ, the quote governs.

California has 12 of 16 core fields verified. The remaining 4 are listed in the overview. When one of them is published, the page changes and the "last verified" date moves; until then, the safest assumption is that the answer is unknown, not that it is no.

<a id="gaps"></a>

## What is still open for California

California has 4 of 16 core fields still open, and the reason recorded for each is below.

- **Treatment of affiliates**: Reason recorded: The CalRecycle page does not say whether affiliate sales aggregate toward the $1 million limit. The definition sits in 14 CCR 18980.5.2, which was not read verbatim.
- **The material categories**: Reason recorded: The exact CMC count and machine-readable list were not confirmed. Count 89 is distinct 25_ tokens extracted from the guidance PDF text and includes truncated ids; a taxonomy file must be built from the CalRecycle CMC list page.
- **Labelling**: Reason recorded: No producer labelling rule was found in the sources read. Confirm against 14 CCR Article 6 before relying on required=false.
- **Filing languages**: Reason recorded: No page states a filing-language rule. English is recorded because the portal and forms are English only; confirm with CalRecycle.

<a id="gaps-meaning"></a>

## What an open field means in practice

A field is marked not yet published when no primary source we can cite says what it needs to say. Below, each open field for California is listed with the reason we recorded and what it means for a business that sells there while the field stays open.

- **Treatment of affiliates**: Whether affiliates are added together affects group companies; keep group revenue and tonnage by entity.
- **The material categories**: Material categories decide how packaging is grouped for fees; weigh and record packaging by material so any grouping can be applied.
- **Labelling**: Labelling rules decide whether a pack needs a mark or a sorting instruction; check pack artwork before printing a large run.
- **Filing languages**: The filing language decides whether you need a translation of your report; confirm before you prepare the file.

We re-check open fields when a source changes and when a reviewer flags one. If you hold a primary source that answers an open field for California, the data-gaps page explains how to send it; we publish a field only after we can cite the source and its date.

<a id="scenarios"></a>

## What this means for different sellers in California

Because California records a packaging EPR obligation, each of the following sellers should expect to do some work. What differs is who the producer is and which threshold applies.

#### A brand owner that makes or packs its own goods

You are the likeliest producer. Count the packaging you put into California by material, compare it with the thresholds, and register (the dataset records that registration is required). Keep the weights; every later step starts from them.

#### An importer or reseller of branded goods

Importers are named producers in many regimes. Check the producer roles above: if the importer is listed for a packaging level, the duty for that pack can move to you from the brand owner, and the brand owner may ask for proof that you handle it.

#### A seller that ships through an online marketplace

Some regimes make the marketplace answerable and some leave the duty with you. This page lists the roles recorded for California; where the marketplace role is not listed, assume you remain responsible and check the marketplace's own seller guidance.

#### A small seller that sells only a few parcels a year

Compare your figures with the 1 verified threshold above. Being under a threshold can mean no fee, a simplified report or only a registration; read the effect column, because it is not always full relief.

<a id="mistakes"></a>

## Common mistakes with California packaging EPR

Most problems with packaging EPR do not come from the rule itself; they come from a few repeated slips. These are the ones to avoid when you work from the records for California.

- Treating "not yet published" as "no". An open field means we do not know, and the safe reading is that a duty may exist.
- Using another place's threshold. California sets its own figures (see the table); a neighbour's number does not carry over.
- Measuring in the wrong unit. Thresholds are written in kilograms, tonnes or a currency; convert before you compare.
- Counting the wrong period. The period a deadline covers is part of the rule, and the table shows it where it is published.
- Assuming a marketplace or a supplier handles reporting. Confirm in writing who the producer is for each pack and who is responsible for submission.
- Filing on a calendar you copied from last year. Dates move; use the dated records on this page and recheck near the deadline.

The records show what the published sources say. A decision with real exposure belongs with the regulator or a qualified adviser.

<a id="faq"></a>

## Questions about packaging EPR in California

### <a id="faq-obliged"></a>Do I need to take part in packaging EPR in California?

California records a packaging EPR obligation for producers, with thresholds that decide who is in scope; compare your figures with the thresholds table. Whether you are the producer depends on the roles listed for each packaging level.

### <a id="faq-who"></a>Who is the regulator in California?

The regulator recorded for California is CalRecycle (Department of Resources Recycling and Recovery), through its PEPRS portal.

### <a id="faq-threshold"></a>Is there a small-business threshold in California?

California records 1 verified threshold; see the table above for the amounts and what each one changes.

### <a id="faq-deadline"></a>When are filings due in California?

California records 3 verified deadlines; they are listed with the period each covers.

### <a id="faq-register"></a>Do I have to register in California?

Yes, the dataset records that registration is required in California.

### <a id="faq-submit"></a>Does Instica file my report?

No. We measure your packaging, estimate what you may owe and prepare the report file. You review it, sign it and submit it yourself, and Instica never stores regulator-portal credentials.

### <a id="faq-source"></a>How do I know the data is current?

Each record shows the source address and the date we retrieved it. This page was last verified on September 29, 2026.

### <a id="faq-legal"></a>Can I rely on this page for a decision?

It summarizes published sources to help you prepare. For a decision that carries real risk, ask the regulator or a qualified adviser.

<a id="estimate"></a>

> **Estimate**: Figures here are estimates prepared from published sources, not a ruling. You review, sign and submit your own filings; Instica does not store regulator-portal credentials and does not submit for you.

<a id="epr-cite-facts"></a>

## Facts on this page

Each fact is a self-contained sentence with its source. Link to a fact with its anchor.

- The packaging EPR regime in California is recorded as California SB 54, Plastic Pollution Prevention and Packaging Producer Responsibility Act (Public Resources Code, Division 30, Part 3, Chapter 3.1). [#regime](#regime)
  Value: California SB 54, Plastic Pollution Prevention and Packaging Producer Responsibility Act (Public Resources Code, Division 30, Part 3, Chapter 3.1) · Source: https://calrecycle.ca.gov/packaging/packaging-epr/ · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: SB 54 establishes a new extended producer responsibility (EPR) program to manage packaging and single-use plastic food service ware products (en)
- The regulator named for California is CalRecycle (Department of Resources Recycling and Recovery), through its PEPRS portal. [#regulator](#regulator)
  Value: CalRecycle (Department of Resources Recycling and Recovery), through its PEPRS portal · Source: https://calrecycle.ca.gov/packaging/packaging-epr/producerguidance/ · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: PEPRS is CalRecycle’s online portal for: Producer Registration Data Submission Compliance Tracking (en)
- Producers placing packaging on the market in California carry a packaging EPR obligation. [#obligated](#obligated)
  Value: yes · Source: https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=PRC&sectionNum=42051 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: a producer shall not sell, offer for sale, import, or distribute covered materials in the state unless the producer is approved to participate (en)
- In California, the party that carries the obligation by default is the manufacturer or brand owner, licensee, and first distributor. [#producer-default](#producer-default)
  Value: first distributor, licensee, and manufacturer or brand owner · Source: https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=PRC&sectionNum=42041 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: the producer of the covered material is the person who sells, offers for sale, or distributes the product that uses the covered material (en)
- In California, the obligation cannot be transferred to another party. [#transfer](#transfer)
  Value: no · Source: https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=PRC&sectionNum=42041 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: The owner or operator of the online marketplace shall not be considered the retailer or wholesaler for such sales. (en)
- Where a revenue test applies in California, it is measured on revenue earned in the jurisdiction over calendar year, in USD. [#revenue-scope](#revenue-scope)
  Value: in_jurisdiction · Source: https://www2.calrecycle.ca.gov/Docs/Web/138910 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Enter the amount of total gross annual sales (U.S. dollar) in California, as found on the most recent calendar year's tax returns. (en)
- Whether affiliates are counted together in California: not yet published. Reason: The CalRecycle page does not say whether affiliate sales aggregate toward the $1 million limit. The definition sits in 14 CCR 18980.5.2, which was not read verbatim. [#affiliates](#affiliates)
  Value: not yet published · Source: https://calrecycle.ca.gov/packaging/packaging-epr/exemptionsexclusions/ · Retrieved: September 29, 2026 · Status: not yet published
  Verbatim quote: Small producers with gross annual sales of less than $1 million may apply to be exempt from most of the law’s reporting and fee requirements. (en)
- California sets a revenue threshold of below $1,000,000.00; effect: the producer is exempt below it. [#threshold-small_producer_gross_annual_sales](#threshold-small_producer_gross_annual_sales)
  Value: $1,000,000 · Source: https://calrecycle.ca.gov/packaging/packaging-epr/exemptionsexclusions/ · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Small producers with gross annual sales of less than $1 million may apply to be exempt from most of the law’s reporting and fee requirements. (en)
- Exemption in California: Temporary, renewable exemption from most reporting and fee requirements for producers with gross annual California sales under $1 million. Long-term duty remains: all packaging recyclable or compostable by 2032. You must apply for it. [#exemption-small_producer](#exemption-small_producer)
  Value: small_producer · Source: https://calrecycle.ca.gov/packaging/packaging-epr/exemptionsexclusions/ · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: To apply, first register in CalRecycle’s reporting system, known as PEPRS, as a Packaging EPR producer. Then fill out the small producer exemption application. (en)
- Exemption in California: A person who produces, harvests and packages an agricultural commodity on the site where it was grown or raised is not a producer. It applies without a separate application. [#exemption-agricultural_commodity_on_site](#exemption-agricultural_commodity_on_site)
  Value: agricultural_commodity_on_site · Source: https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=PRC&sectionNum=42041 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: “Producer” does not include a person who produces, harvests, and packages an agricultural commodity on the site where the agricultural commodity was grown or raised. (en)
- Exemption in California: Beverage containers subject to the California Beverage Container Recycling and Litter Reduction Act are not covered material. It applies without a separate application. [#exemption-crv_beverage_containers](#exemption-crv_beverage_containers)
  Value: crv_beverage_containers · Source: https://www2.calrecycle.ca.gov/Docs/Web/131538 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Beverage containers subject to the California Beverage Container Recycling and Litter Reduction Act (Division 12.1 (commencing with Section 14500)). (en)
- Exemption in California: Covered material meeting a 65% (through 2026) or 70% (2027 on) recycling rate, outside curbside collection and commingled sorting, recycled at responsible end markets, is not covered material once CalRecycle approves the producer's demonstration. You must apply for it. [#exemption-high_recycling_rate_material](#exemption-high_recycling_rate_material)
  Value: high_recycling_rate_material · Source: https://calrecycle.ca.gov/packaging/packaging-epr/exemptionsexclusions/ · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Achieve 65% recycling rates from 2024 to 2026, and 70% in 2027 and after (en)
- Producers in California must register with PEPRS (CalRecycle Packaging Extended Producer Responsibility System). [#registration](#registration)
  Value: yes · Source: https://calrecycle.ca.gov/packaging/packaging-epr/producerguidance/ · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Circular Action Alliance manages registration, reporting, and submissions of certain exemptions and exclusions on the producers’ behalf. (en)
- In California, the system runs through a single producer responsibility organisation: Circular Action Alliance; membership is required. [#organisation](#organisation)
  Value: one producer responsibility organisation · Source: https://calrecycle.ca.gov/packaging/packaging-epr/ · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Circular Action Alliance has been approved to serve as the first Producer Responsibility Organization. (en)
- The material categories in California: not yet published. Reason: The exact CMC count and machine-readable list were not confirmed. Count 89 is distinct 25_ tokens extracted from the guidance PDF text and includes truncated ids; a taxonomy file must be built from the CalRecycle CMC list page. [#categories](#categories)
  Value: not yet published · Source: https://www2.calrecycle.ca.gov/Docs/Web/131538 · Retrieved: September 29, 2026 · Status: not yet published
  Verbatim quote: Category IDs ending with “N” indicate the category is for material without a plastic component (en)
- Labelling in California: not yet published. Reason: No producer labelling rule was found in the sources read. Confirm against 14 CCR Article 6 before relying on required=false. [#labelling](#labelling)
  Value: not yet published · Source: https://calrecycle.ca.gov/packaging/packaging-epr/ · Retrieved: September 29, 2026 · Status: not yet published
  Verbatim quote: Consumers are educated and informed on recycling practices (en)
- Languages in California: not yet published. Reason: No page states a filing-language rule. English is recorded because the portal and forms are English only; confirm with CalRecycle. [#languages](#languages)
  Value: not yet published · Source: https://calrecycle.ca.gov/packaging/packaging-epr/producerguidance/ · Retrieved: November 3, 2026 · Status: not yet published
  Verbatim quote: PEPRS is CalRecycle’s online portal for: Producer Registration Data Submission Compliance Tracking (en)
- California sets a target for plastic source reduction: 10 by January 1, 2027. [#target-source_reduction_2027](#target-source_reduction_2027)
  Value: 10 · Source: https://calrecycle.ca.gov/packaging/packaging-epr/producerguidance/ · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: 65% Single-Use Plastic Recycled (en)
- California sets a target for plastic source reduction: 20 by January 1, 2030. [#target-source_reduction_2030](#target-source_reduction_2030)
  Value: 20 · Source: https://calrecycle.ca.gov/packaging/packaging-epr/producerguidance/ · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: 65% Single-Use Plastic Recycled (en)
- California sets a target for plastic source reduction: 25 by January 1, 2032. [#target-source_reduction_2032](#target-source_reduction_2032)
  Value: 25 · Source: https://calrecycle.ca.gov/packaging/packaging-epr/producerguidance/ · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: 65% Single-Use Plastic Recycled (en)
- California sets a target for plastic recycling rate: 30 percent by January 1, 2028. [#target-plastic_recycling_2028](#target-plastic_recycling_2028)
  Value: 30 · Source: https://calrecycle.ca.gov/packaging/packaging-epr/producerguidance/ · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: 65% Single-Use Plastic Recycled (en)
- California sets a target for plastic recycling rate: 40 percent by January 1, 2030. [#target-plastic_recycling_2030](#target-plastic_recycling_2030)
  Value: 40 · Source: https://calrecycle.ca.gov/packaging/packaging-epr/producerguidance/ · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: 65% Single-Use Plastic Recycled (en)
- California sets a target for plastic recycling rate: 65 percent by January 1, 2032. [#target-plastic_recycling_2032](#target-plastic_recycling_2032)
  Value: 65 · Source: https://calrecycle.ca.gov/packaging/packaging-epr/producerguidance/ · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: 65% Single-Use Plastic Recycled (en)
- California sets a target for recyclable or compostable share: 100 percent by January 1, 2032. [#target-recyclable_or_compostable_2032](#target-recyclable_or_compostable_2032)
  Value: 100 · Source: https://calrecycle.ca.gov/packaging/packaging-epr/producerguidance/ · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: 65% Single-Use Plastic Recycled (en)
- California sets a penalty for failure to comply with the chapter or its regulations: up to $50,000 per day per violation. Escalation: reduced to 25000 for entities meeting PRC 42060(a)(5); accrues from 30 days after notice of violation. [#penalty-1](#penalty-1)
  Value: $50,000 · Source: https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=PRC&sectionNum=42081 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: an administrative civil penalty not to exceed fifty thousand dollars ($50,000) per day per violation (en)
- <a id="cmp-US-OR-obligated"></a>Oregon carries a packaging EPR obligation. [#cmp-US-OR-obligated](#cmp-US-OR-obligated)
  Value: yes · Source: https://oregon.public.law/statutes/ors_459A.869 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: each producer must register with and be a member of a producer responsibility organization that administers a producer responsibility program (en)
- The regime in Oregon is recorded as Oregon Recycling Modernization Act, ORS 459A.860 to 459A.975 (SB 582 of 2021). [#cmp-US-OR-regime](#cmp-US-OR-regime)
  Value: Oregon Recycling Modernization Act, ORS 459A.860 to 459A.975 (SB 582 of 2021) · Source: https://www.oregon.gov/deq/recycling/pages/producers-of-covered-products.aspx · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: producers of products covered under Oregon's Recycling Modernization Act (packaging, paper, and food serviceware) (en)
- <a id="cmp-US-OR-regulator"></a>The regulator in Oregon is Oregon Department of Environmental Quality (DEQ). [#cmp-US-OR-regulator](#cmp-US-OR-regulator)
  Value: Oregon Department of Environmental Quality (DEQ) · Source: https://www.oregon.gov/deq/recycling/pages/producers-of-covered-products.aspx · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Circular Action Alliance, at present, is Oregon's only approved Producer Responsibility Organization (en)
- Oregon runs its system through a single producer responsibility organisation: Circular Action Alliance. [#cmp-US-OR-organisation](#cmp-US-OR-organisation)
  Value: one producer responsibility organisation · Source: https://www.oregon.gov/deq/recycling/pages/producers-of-covered-products.aspx · Retrieved: November 5, 2026 · Status: verified
  Verbatim quote: Circular Action Alliance, at present, is Oregon's only approved Producer Responsibility Organization (en)
- <a id="cmp-US-OR-registration"></a>Oregon requires registration: Circular Action Alliance producer portal (PRO registration); DEQ holds no separate producer registry. [#cmp-US-OR-registration](#cmp-US-OR-registration)
  Value: yes · Source: https://www.oregon.gov/deq/recycling/pages/producers-of-covered-products.aspx · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: In order to access CAA's data reporting portal, producers must first sign the Producer Participant Agreement with CAA (en)
- Oregon sets a revenue threshold of below $5,000,000.00. [#cmp-US-OR-threshold](#cmp-US-OR-threshold)
  Value: $5,000,000 · Source: https://oregon.public.law/statutes/ors_459A.863 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Has a gross revenue of less than $5 million for the organization's most recent fiscal year (en)
- Oregon has a reporting deadline on May 31, 2026. [#cmp-US-OR-deadline](#cmp-US-OR-deadline)
  Value: May 31, 2026 · Source: https://circularactionalliance.org/producer-reporting · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Oregon's 2026 Report is due May 31, 2026, based on the 2025 Data Year. (en)
- <a id="cmp-US-CO-obligated"></a>Colorado carries a packaging EPR obligation. [#cmp-US-CO-obligated](#cmp-US-CO-obligated)
  Value: yes · Source: https://cdphe.colorado.gov/producer-responsibility-program · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: a producer cannot sell or distribute products that use covered materials in Colorado unless they participate in the Producer Responsibility Program (en)
- The regime in Colorado is recorded as Colorado Producer Responsibility Program for Statewide Recycling Act, C.R.S. 25-17-701 et seq. (HB22-1355). [#cmp-US-CO-regime](#cmp-US-CO-regime)
  Value: Colorado Producer Responsibility Program for Statewide Recycling Act, C.R.S. 25-17-701 et seq. (HB22-1355) · Source: https://cdphe.colorado.gov/producer-responsibility-program · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: In 2022, Governor Polis signed the Producer Responsibility Program for Statewide Recycling Act into law (en)
- <a id="cmp-US-CO-regulator"></a>The regulator in Colorado is Colorado Department of Public Health and Environment (CDPHE), Solid Waste and Materials Management Program. [#cmp-US-CO-regulator](#cmp-US-CO-regulator)
  Value: Colorado Department of Public Health and Environment (CDPHE), Solid Waste and Materials Management Program · Source: https://cdphe.colorado.gov/producer-responsibility-program · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: CDPHE appointed Circular Action Alliance as the designated Producer Responsibility Organization in May 2023. (en)
- Colorado runs its system through more than one producer responsibility organisation: Circular Action Alliance and Interchange 360 (automotive lubricant packaging, individual programme). [#cmp-US-CO-organisation](#cmp-US-CO-organisation)
  Value: several competing organisations · Source: https://cdphe.colorado.gov/producer-responsibility-program · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Interchange 360 manages the recycling of automotive lubricant packaging, such as motor oil and antifreeze. (en)
- <a id="cmp-US-CO-registration"></a>Colorado requires registration with Circular Action Alliance producer portal. [#cmp-US-CO-registration](#cmp-US-CO-registration)
  Value: yes · Source: https://cdphe.colorado.gov/producer-responsibility-program · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: All producers of paper products and packaging materials should register with Circular Action Alliance and submit a supply report. (en)
- Colorado sets a revenue threshold of below $5,000,000.00. [#cmp-US-CO-threshold](#cmp-US-CO-threshold)
  Value: $5,000,000 · Source: https://colorado.public.law/statutes/crs_25-17-713 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: A person with less than five million dollars in realized gross total revenue, not including on-premises alcohol sales, during the prior calendar year (en)
- Colorado has a payment deadline on January 1, 2026. [#cmp-US-CO-deadline](#cmp-US-CO-deadline)
  Value: January 1, 2026 · Source: https://colorado.public.law/statutes/crs_25-17-709 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: no later than January 1, 2026, and annually thereafter by a date determined by the organization (en)
- <a id="cmp-US-WA-obligated"></a>Washington carries a packaging EPR obligation. [#cmp-US-WA-obligated](#cmp-US-WA-obligated)
  Value: yes · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: After July 1, 2026, be a member of a producer responsibility organization registered in this state (en)
- The regime in Washington is recorded as Washington Recycling Reform Act, chapter 70A.208 RCW. [#cmp-US-WA-regime](#cmp-US-WA-regime)
  Value: Washington Recycling Reform Act, chapter 70A.208 RCW · Source: https://circularactionalliance.org/washington · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: required in the Recycling Reform Act (en)
- <a id="cmp-US-WA-regulator"></a>The regulator in Washington is Washington State Department of Ecology. [#cmp-US-WA-regulator](#cmp-US-WA-regulator)
  Value: Washington State Department of Ecology · Source: https://circularactionalliance.org/washington · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: By January 1, 2026 Washington Department of Ecology must establish and appoint the initial membership of the advisory council. (en)
- Washington runs its system through a single producer responsibility organisation: Circular Action Alliance. [#cmp-US-WA-organisation](#cmp-US-WA-organisation)
  Value: one producer responsibility organisation · Source: https://ecology.wa.gov/waste-toxics/reducing-recycling-waste/our-recycling-programs/recycling-reform-act/producer-responsibility-organization · Retrieved: November 5, 2026 · Status: verified
  Verbatim quote: The Circular Action Alliance is the PRO representing producers in Washington. We encourage all potentially obligated producers to register with CAA. (en)
- <a id="cmp-US-WA-registration"></a>Washington requires registration: Producer registers with a PRO; the PRO registers with Ecology. [#cmp-US-WA-registration](#cmp-US-WA-registration)
  Value: yes · Source: https://circularactionalliance.org/washington · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: July 1, 2026 Washington regulatory deadline for Producers to register with a PRO. (en)
- Washington sets a tonnage threshold of below 1 short ton. [#cmp-US-WA-threshold](#cmp-US-WA-threshold)
  Value: 1 short ton · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: In their most recent fiscal year introduced less than one ton of covered materials (en)
- Washington has a deadline of another kind on March 1, 2026. [#cmp-US-WA-deadline](#cmp-US-WA-deadline)
  Value: March 1, 2026 · Source: https://circularactionalliance.org/washington · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: By March 1, 2026 A PRO must register with Washington Department of Ecology on behalf of its producers. (en)
- <a id="cmp-US-ME-obligated"></a>Maine carries a packaging EPR obligation. [#cmp-US-ME-obligated](#cmp-US-ME-obligated)
  Value: yes · Source: https://legislature.maine.gov/statutes/38/title38sec2146.html · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: a producer is exempt from the requirements and prohibitions of this section in any calendar year in which: (en)
- The regime in Maine is recorded as Maine Stewardship Program for Packaging, 38 M.R.S. section 2146. [#cmp-US-ME-regime](#cmp-US-ME-regime)
  Value: Maine Stewardship Program for Packaging, 38 M.R.S. section 2146 · Source: https://www.maine.gov/dep/waste/recycle/epr.html · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: In July 2021, the Legislature passed a law establishing Maine’s Stewardship Program for Packaging, 38 M.R.S. § 2146. (en)
- <a id="cmp-US-ME-regulator"></a>The regulator in Maine is Maine Department of Environmental Protection. [#cmp-US-ME-regulator](#cmp-US-ME-regulator)
  Value: Maine Department of Environmental Protection · Source: https://legislature.maine.gov/statutes/38/title38sec2146.html · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: The department shall administer and enforce this section and shall adopt rules as necessary to implement, administer and enforce this section. (en)
- Maine runs its system through a single producer responsibility organisation. [#cmp-US-ME-organisation](#cmp-US-ME-organisation)
  Value: one producer responsibility organisation · Source: https://www.maine.gov/dep/waste/recycle/epr.html · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Maine DEP to Revise Request for Proposals for Stewardship Organization. (September 11, 2026) (en)
- <a id="cmp-US-ME-registration"></a>Maine requires registration: Producers register with the stewardship organization (not yet contracted). [#cmp-US-ME-registration](#cmp-US-ME-registration)
  Value: yes · Source: https://www.maine.gov/dep/waste/recycle/epr.html · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Within 90 days of the SO making a registration mechanism available, producers must register with the SO. (en)
- Maine sets a revenue threshold of below $2,000,000.00. [#cmp-US-ME-threshold](#cmp-US-ME-threshold)
  Value: $2,000,000 · Source: https://legislature.maine.gov/statutes/38/title38sec2146.html · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: The producer realized less than $2,000,000 in total gross revenue during the prior calendar year (en)
- Maine has a reporting deadline on May 31, 2027. [#cmp-US-ME-deadline](#cmp-US-ME-deadline)
  Value: May 31, 2027 · Source: https://www.maine.gov/dep/waste/recycle/epr.html · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Producers of packaging material will annually report to the SO by May 31. (en)
- <a id="cmp-US-MN-obligated"></a>Minnesota carries a packaging EPR obligation. [#cmp-US-MN-obligated](#cmp-US-MN-obligated)
  Value: yes · Source: https://circularactionalliance.org/minnesota · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Producers must be a member of a PRO that is registered with MPCA by July 1, 2025. (en)
- The regime in Minnesota is recorded as Minnesota packaging EPR law, Minnesota Statutes sections 115A.144 to 115A.1463. [#cmp-US-MN-regime](#cmp-US-MN-regime)
  Value: Minnesota packaging EPR law, Minnesota Statutes sections 115A.144 to 115A.1463 · Source: https://www.revisor.mn.gov/statutes/cite/115A.1441 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: requirements under sections 115A.144 to 115A.1463 (en)
- <a id="cmp-US-MN-regulator"></a>The regulator in Minnesota is Minnesota Pollution Control Agency. [#cmp-US-MN-regulator](#cmp-US-MN-regulator)
  Value: Minnesota Pollution Control Agency · Source: https://circularactionalliance.org/minnesota · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: the Minnesota Pollution Control Agency (MPCA) confirmed CAA’s registration to implement the state’s EPR program. (en)
- Minnesota runs its system through a single producer responsibility organisation: Circular Action Alliance. [#cmp-US-MN-organisation](#cmp-US-MN-organisation)
  Value: one producer responsibility organisation · Source: https://web.archive.org/web/20261016213413/https://www.pca.state.mn.us/news-and-stories/mpca-confirms-registration-of-minnesotas-initial-packaging-producer-responsibility-organization · Retrieved: November 5, 2026 · Status: verified
  Verbatim quote: the MPCA confirmed Circular Action Alliance (CAA) — a 501(c)(3) nonprofit, producer-led organization — as Minnesota’s initial PRO. (en)
- <a id="cmp-US-MN-registration"></a>Minnesota requires registration: Producer joins a PRO; the PRO registers with the MPCA. [#cmp-US-MN-registration](#cmp-US-MN-registration)
  Value: yes · Source: https://circularactionalliance.org/minnesota · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Producers must be a member of a PRO that is registered with MPCA by July 1, 2025. (en)
- Minnesota sets a tonnage threshold of below 1 short ton. [#cmp-US-MN-threshold](#cmp-US-MN-threshold)
  Value: 1 short ton · Source: https://www.revisor.mn.gov/statutes/cite/115A.1441 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: introduced less than one ton of covered material into this state (en)
- Minnesota has a registration deadline on July 1, 2026. [#cmp-US-MN-deadline](#cmp-US-MN-deadline)
  Value: July 1, 2026 · Source: https://www.revisor.mn.gov/statutes/cite/115A.1443 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: The producer responsibility organization must register with the commissioner by July 1, 2026, and each January 1 thereafter (en)
- <a id="cmp-US-MD-obligated"></a>Maryland carries a packaging EPR obligation. [#cmp-US-MD-obligated](#cmp-US-MD-obligated)
  Value: yes · Source: https://mgaleg.maryland.gov/2025RS/bills/sb/sb0901E.pdf · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: A PRODUCER MAY NOT SELL, OFFER FOR SALE, DISTRIBUTE, OR IMPORT FOR SALE OR DISTRIBUTION PACKAGING COVERED MATERIALS FOR USE IN THE STATE UNLESS (en)
- The regime in Maryland is recorded as Maryland packaging and paper products producer responsibility law (SB 901, 2025). [#cmp-US-MD-regime](#cmp-US-MD-regime)
  Value: Maryland packaging and paper products producer responsibility law (SB 901, 2025) · Source: https://circularactionalliance.org/maryland · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: In May 2025, Maryland passed SB 901, an Extended Producer Responsibility (en)
- <a id="cmp-US-MD-regulator"></a>The regulator in Maryland is Maryland Department of the Environment. [#cmp-US-MD-regulator](#cmp-US-MD-regulator)
  Value: Maryland Department of the Environment · Source: https://circularactionalliance.org/maryland · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Maryland Department of the Environment a list of producers, brands and material type information. (en)
- Maryland runs its system through a single producer responsibility organisation: Circular Action Alliance. [#cmp-US-MD-organisation](#cmp-US-MD-organisation)
  Value: one producer responsibility organisation · Source: https://circularactionalliance.org/maryland · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: serve as the single nonprofit PRO on the State Producer Responsibility Advisory Council (en)
- <a id="cmp-US-MD-registration"></a>Maryland requires registration: Producer registers with the PRO (CAA); the PRO files the producer list with MDE. [#cmp-US-MD-registration](#cmp-US-MD-registration)
  Value: yes · Source: https://circularactionalliance.org/maryland · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Producers must register with CAA by May 31, 2026 (en)
- Maryland sets a tonnage threshold of below 1 short ton. [#cmp-US-MD-threshold](#cmp-US-MD-threshold)
  Value: 1 short ton · Source: https://mgaleg.maryland.gov/2025RS/bills/sb/sb0901E.pdf · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: INTRODUCED LESS THAN 1 TON OF COVERED MATERIAL INTO THE STATE (en)
- Maryland has a registration deadline on May 31, 2026. [#cmp-US-MD-deadline](#cmp-US-MD-deadline)
  Value: May 31, 2026 · Source: https://circularactionalliance.org/maryland · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Producers must register with CAA by May 31, 2026 (en)
- <a id="cmp-GB-obligated"></a>United Kingdom carries a packaging EPR obligation. [#cmp-GB-obligated](#cmp-GB-obligated)
  Value: yes · Source: https://www.gov.uk/guidance/check-if-you-must-comply-with-epr-for-packaging--2 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: you supplied or imported more than 25 tonnes of packaging in the UK in the previous year (en)
- The regime in United Kingdom is recorded as Extended producer responsibility (EPR) for packaging, under the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024. [#cmp-GB-regime](#cmp-GB-regime)
  Value: Extended producer responsibility (EPR) for packaging, under the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 · Source: https://www.gov.uk/guidance/how-to-comply-with-packaging-recycling-obligations-as-a-large-producer · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: go to schedule 5 of the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (as amended) (en)
- <a id="cmp-GB-regulator"></a>The regulator in United Kingdom is Four environmental regulators (Environment Agency, Natural Resources Wales, SEPA, NIEA); PackUK is the scheme administrator that sets fees. [#cmp-GB-regulator](#cmp-GB-regulator)
  Value: Four environmental regulators (Environment Agency, Natural Resources Wales, SEPA, NIEA); PackUK is the scheme administrator that sets fees · Source: https://www.gov.uk/guidance/epr-for-packaging-what-you-must-do-as-a-small-producer · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Each of the 4 nations of the United Kingdom has its own regulator. You’ll be reporting to and monitored by the regulator for your nation. (en)
- United Kingdom runs its system through registered schemes that producers join. [#cmp-GB-organisation](#cmp-GB-organisation)
  Value: compliance schemes · Source: https://www.gov.uk/guidance/epr-for-packaging-what-you-must-do-as-a-small-producer · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Compliance schemes are third parties that help organisations meet the EPR for packaging requirements. (en)
- <a id="cmp-GB-registration"></a>United Kingdom requires registration with Report packaging data (RPD) service, run by Defra and the regulators. [#cmp-GB-registration](#cmp-GB-registration)
  Value: yes · Source: https://www.gov.uk/guidance/epr-for-packaging-what-you-must-do-as-a-small-producer · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: the fee is: £1,303 if you register directly with your environmental regulator £696 if you register through a compliance scheme (en)
- United Kingdom sets a tonnage threshold of above 25 tonnes. [#cmp-GB-threshold](#cmp-GB-threshold)
  Value: 25 tonnes · Source: https://www.gov.uk/guidance/check-if-you-must-comply-with-epr-for-packaging--2 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: you supplied or imported more than 25 tonnes of packaging in the UK in the previous year (en)
- United Kingdom has a reporting deadline on October 1, 2026. [#cmp-GB-deadline](#cmp-GB-deadline)
  Value: October 1, 2026 · Source: https://www.gov.uk/guidance/packaging-data-check-reporting-periods-and-submission-deadlines · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: 1 January to 30 June 2026 1 October 2026 (en)
- <a id="cmp-BE-obligated"></a>Belgium carries a packaging EPR obligation. [#cmp-BE-obligated](#cmp-BE-obligated)
  Value: yes · Source: https://www.fostplus.be/en/members/become-a-fost-plus-member · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Does your company put household packaging on the market? Then you have an obligation to report on this packaging to the government. (en)
- The regime in Belgium is recorded as Belgian interregional Cooperation Agreement on packaging waste, in force in its current version since 5 March 2020; enforced by the Interregional Packaging Commission (IRPC/IVC-CIE). [#cmp-BE-regime](#cmp-BE-regime)
  Value: Belgian interregional Cooperation Agreement on packaging waste, in force in its current version since 5 March 2020; enforced by the Interregional Packaging Commission (IRPC/IVC-CIE) · Source: https://valipac.academy/en/modules/gaining-a-better-understanding-of-the-legislation/belgian-legislative-framework/ · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: The new version of the Cooperation Agreement has been in force since 5 March 2020. (en)
- <a id="cmp-BE-regulator"></a>The regulator in Belgium is Interregional Packaging Commission (IVC-CIE, now EPRiBEL). [#cmp-BE-regulator](#cmp-BE-regulator)
  Value: Interregional Packaging Commission (IVC-CIE, now EPRiBEL) · Source: https://valipac.academy/en/modules/gaining-a-better-understanding-of-the-legislation/belgian-legislative-framework/ · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: The Interregional Packaging Commission is responsible for the enforcement of the Cooperation Agreement. (en)
- Belgium runs its system through more than one producer responsibility organisation: Fost Plus (household) and Valipac (industrial). [#cmp-BE-organisation](#cmp-BE-organisation)
  Value: several competing organisations · Source: https://www.fostplus.be/en/blog/ppwr-insights-8-mandatory-registration-in-producer-register-fost-plus-handles-it-for-you · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: This representative must (1) be established in Belgium and (2) be registered with EPRiBEL. (en)
- <a id="cmp-BE-registration"></a>Belgium requires registration: EPRiBEL producer register (formerly IVC-CIE); Fost Plus registers members collectively. [#cmp-BE-registration](#cmp-BE-registration)
  Value: yes · Source: https://www.fostplus.be/en/blog/ppwr-insights-8-mandatory-registration-in-producer-register-fost-plus-handles-it-for-you · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Companies that are not members of Fost Plus or another recognised EPR organisation can register directly through EPRiBEL (en)
- Belgium sets a tonnage threshold of 300 tonnes of single-use packaging per year. [#cmp-BE-threshold](#cmp-BE-threshold)
  Value: 300 tonnes of single-use packaging per year · Source: https://www.fostplus.be/en/members/become-a-fost-plus-member · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: companies that put at least 300 tonnes of single-use packaging on the market annually (en)
- Belgium has a deadline of another kind on September 15, 2026. [#cmp-BE-deadline](#cmp-BE-deadline)
  Value: September 15, 2026 · Source: https://www.fostplus.be/en/members/declaration · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Exceptionally, you can still amend your 2025 declaration until 15 September this year. (en)

## Related pages

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- [EPR jurisdictions dataset](https://instica.com/epr/jurisdictions)
- [EPR data sources](https://instica.com/epr/methodology)

### In this section

- [California EPR do I have to register](https://instica.com/epr/california/deadlines)
- [Do I owe EPR fees California](https://instica.com/epr/california/do-i-owe)
- [Sell on direct sales EPR California](https://instica.com/epr/for/direct/california)
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### Related comparisons

- [Alberta vs California EPR: Rules Compared](https://instica.com/epr/compare/alberta-vs-california)
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- [California vs New Brunswick EPR: Rules Compared](https://instica.com/epr/compare/california-vs-new-brunswick)
- [California vs Saskatchewan EPR: Rules Compared](https://instica.com/epr/compare/california-vs-saskatchewan)
- [California vs Washington EPR: Rules Compared](https://instica.com/epr/compare/california-vs-washington)

### More for this jurisdiction

- [California packaging EPR requirements](https://instica.com/epr/california/updates)

### Neighbouring jurisdictions

- [Glass and ceramics extended producer responsibility Oregon](https://instica.com/epr/oregon)

### Related pages

- [Paper products EPR fees Colorado](https://instica.com/epr/colorado)
- [Maine EPR obligation](https://instica.com/epr/maine)
- [Maryland EPR obligation](https://instica.com/epr/maryland)
- [Minnesota EPR fee rates 2026](https://instica.com/epr/minnesota)
- [Washington EPR reporting format](https://instica.com/epr/washington)

## Sources

1. calrecycle.ca.gov: packaging epr (https://calrecycle.ca.gov/packaging/packaging-epr/), Retrieved: September 29, 2026, Status: verified
   > SB 54 establishes a new extended producer responsibility (EPR) program to manage packaging and single-use plastic food service ware products (en)
2. calrecycle.ca.gov: producerguidance (https://calrecycle.ca.gov/packaging/packaging-epr/producerguidance/), Retrieved: September 29, 2026, Status: verified
   > PEPRS is CalRecycle’s online portal for: Producer Registration Data Submission Compliance Tracking (en)
3. leginfo.legislature.ca.gov: codes displaySection.xhtml (https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=PRC&sectionNum=42051), Retrieved: September 29, 2026, Status: verified
   > a producer shall not sell, offer for sale, import, or distribute covered materials in the state unless the producer is approved to participate (en)
4. leginfo.legislature.ca.gov: codes displaySection.xhtml (https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=PRC&sectionNum=42041), Retrieved: September 29, 2026, Status: verified
   > the producer of the covered material is the person who sells, offers for sale, or distributes the product that uses the covered material (en)
5. leginfo.legislature.ca.gov: codes displaySection.xhtml (https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=PRC&sectionNum=42041), Retrieved: September 29, 2026, Status: verified
   > The owner or operator of the online marketplace shall not be considered the retailer or wholesaler for such sales. (en)
6. www2.calrecycle.ca.gov: 138910 (https://www2.calrecycle.ca.gov/Docs/Web/138910), Retrieved: September 29, 2026, Status: verified
   > Enter the amount of total gross annual sales (U.S. dollar) in California, as found on the most recent calendar year's tax returns. (en)
7. calrecycle.ca.gov: exemptionsexclusions (https://calrecycle.ca.gov/packaging/packaging-epr/exemptionsexclusions/), Retrieved: September 29, 2026, Status: not yet published
   > Small producers with gross annual sales of less than $1 million may apply to be exempt from most of the law’s reporting and fee requirements. (en)
8. calrecycle.ca.gov: exemptionsexclusions (https://calrecycle.ca.gov/packaging/packaging-epr/exemptionsexclusions/), Retrieved: September 29, 2026, Status: verified
   > To apply, first register in CalRecycle’s reporting system, known as PEPRS, as a Packaging EPR producer. Then fill out the small producer exemption application. (en)
9. leginfo.legislature.ca.gov: codes displaySection.xhtml (https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=PRC&sectionNum=42041), Retrieved: September 29, 2026, Status: verified
   > “Producer” does not include a person who produces, harvests, and packages an agricultural commodity on the site where the agricultural commodity was grown or raised. (en)
10. www2.calrecycle.ca.gov: 131538 (https://www2.calrecycle.ca.gov/Docs/Web/131538), Retrieved: September 29, 2026, Status: verified
   > Beverage containers subject to the California Beverage Container Recycling and Litter Reduction Act (Division 12.1 (commencing with Section 14500)). (en)
11. calrecycle.ca.gov: exemptionsexclusions (https://calrecycle.ca.gov/packaging/packaging-epr/exemptionsexclusions/), Retrieved: September 29, 2026, Status: verified
   > Achieve 65% recycling rates from 2024 to 2026, and 70% in 2027 and after (en)
12. calrecycle.ca.gov: producerguidance (https://calrecycle.ca.gov/packaging/packaging-epr/producerguidance/), Retrieved: September 29, 2026, Status: verified
   > Circular Action Alliance manages registration, reporting, and submissions of certain exemptions and exclusions on the producers’ behalf. (en)
13. calrecycle.ca.gov: packaging epr (https://calrecycle.ca.gov/packaging/packaging-epr/), Retrieved: September 29, 2026, Status: verified
   > Circular Action Alliance has been approved to serve as the first Producer Responsibility Organization. (en)
14. www2.calrecycle.ca.gov: 131538 (https://www2.calrecycle.ca.gov/Docs/Web/131538), Retrieved: September 29, 2026, Status: not yet published
   > Category IDs ending with “N” indicate the category is for material without a plastic component (en)
15. calrecycle.ca.gov: packaging epr (https://calrecycle.ca.gov/packaging/packaging-epr/), Retrieved: September 29, 2026, Status: not yet published
   > Consumers are educated and informed on recycling practices (en)
16. calrecycle.ca.gov: producerguidance (https://calrecycle.ca.gov/packaging/packaging-epr/producerguidance/), Retrieved: September 29, 2026, Status: verified
   > 65% Single-Use Plastic Recycled (en)
17. leginfo.legislature.ca.gov: codes displaySection.xhtml (https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=PRC&sectionNum=42081), Retrieved: September 29, 2026, Status: verified
   > an administrative civil penalty not to exceed fifty thousand dollars ($50,000) per day per violation (en)
18. oregon.public.law: ors 459A.869 (https://oregon.public.law/statutes/ors_459A.869), Retrieved: September 29, 2026, Status: verified
   > each producer must register with and be a member of a producer responsibility organization that administers a producer responsibility program (en)
19. oregon.gov: producers of covered products (https://www.oregon.gov/deq/recycling/pages/producers-of-covered-products.aspx), Retrieved: September 29, 2026, Status: verified
   > producers of products covered under Oregon's Recycling Modernization Act (packaging, paper, and food serviceware) (en)
20. oregon.gov: producers of covered products (https://www.oregon.gov/deq/recycling/pages/producers-of-covered-products.aspx), Retrieved: September 29, 2026, Status: verified
   > Circular Action Alliance, at present, is Oregon's only approved Producer Responsibility Organization (en)
21. oregon.gov: producers of covered products (https://www.oregon.gov/deq/recycling/pages/producers-of-covered-products.aspx), Retrieved: September 29, 2026, Status: verified
   > In order to access CAA's data reporting portal, producers must first sign the Producer Participant Agreement with CAA (en)
22. oregon.public.law: ors 459A.863 (https://oregon.public.law/statutes/ors_459A.863), Retrieved: September 29, 2026, Status: verified
   > Has a gross revenue of less than $5 million for the organization's most recent fiscal year (en)
23. circularactionalliance.org: producer reporting (https://circularactionalliance.org/producer-reporting), Retrieved: September 29, 2026, Status: verified
   > Oregon's 2026 Report is due May 31, 2026, based on the 2025 Data Year. (en)
24. cdphe.colorado.gov: producer responsibility program (https://cdphe.colorado.gov/producer-responsibility-program), Retrieved: September 29, 2026, Status: verified
   > a producer cannot sell or distribute products that use covered materials in Colorado unless they participate in the Producer Responsibility Program (en)
25. cdphe.colorado.gov: producer responsibility program (https://cdphe.colorado.gov/producer-responsibility-program), Retrieved: September 29, 2026, Status: verified
   > In 2022, Governor Polis signed the Producer Responsibility Program for Statewide Recycling Act into law (en)
26. cdphe.colorado.gov: producer responsibility program (https://cdphe.colorado.gov/producer-responsibility-program), Retrieved: September 29, 2026, Status: verified
   > CDPHE appointed Circular Action Alliance as the designated Producer Responsibility Organization in May 2023. (en)
27. cdphe.colorado.gov: producer responsibility program (https://cdphe.colorado.gov/producer-responsibility-program), Retrieved: September 29, 2026, Status: verified
   > Interchange 360 manages the recycling of automotive lubricant packaging, such as motor oil and antifreeze. (en)
28. cdphe.colorado.gov: producer responsibility program (https://cdphe.colorado.gov/producer-responsibility-program), Retrieved: September 29, 2026, Status: verified
   > All producers of paper products and packaging materials should register with Circular Action Alliance and submit a supply report. (en)
29. colorado.public.law: crs 25 17 713 (https://colorado.public.law/statutes/crs_25-17-713), Retrieved: September 29, 2026, Status: verified
   > A person with less than five million dollars in realized gross total revenue, not including on-premises alcohol sales, during the prior calendar year (en)
30. colorado.public.law: crs 25 17 709 (https://colorado.public.law/statutes/crs_25-17-709), Retrieved: September 29, 2026, Status: verified
   > no later than January 1, 2026, and annually thereafter by a date determined by the organization (en)
31. app.leg.wa.gov: default (https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true), Retrieved: November 3, 2026, Status: verified
   > After July 1, 2026, be a member of a producer responsibility organization registered in this state (en)
32. circularactionalliance.org: washington (https://circularactionalliance.org/washington), Retrieved: September 29, 2026, Status: verified
   > required in the Recycling Reform Act (en)
33. circularactionalliance.org: washington (https://circularactionalliance.org/washington), Retrieved: September 29, 2026, Status: verified
   > By January 1, 2026 Washington Department of Ecology must establish and appoint the initial membership of the advisory council. (en)
34. ecology.wa.gov: producer responsibility organization (https://ecology.wa.gov/waste-toxics/reducing-recycling-waste/our-recycling-programs/recycling-reform-act/producer-responsibility-organization), Retrieved: November 5, 2026, Status: verified
   > The Circular Action Alliance is the PRO representing producers in Washington. We encourage all potentially obligated producers to register with CAA. (en)
35. circularactionalliance.org: washington (https://circularactionalliance.org/washington), Retrieved: September 29, 2026, Status: verified
   > July 1, 2026 Washington regulatory deadline for Producers to register with a PRO. (en)
36. app.leg.wa.gov: default (https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true), Retrieved: November 3, 2026, Status: verified
   > In their most recent fiscal year introduced less than one ton of covered materials (en)
37. circularactionalliance.org: washington (https://circularactionalliance.org/washington), Retrieved: September 29, 2026, Status: verified
   > By March 1, 2026 A PRO must register with Washington Department of Ecology on behalf of its producers. (en)
38. legislature.maine.gov: title38sec2146 (https://legislature.maine.gov/statutes/38/title38sec2146.html), Retrieved: September 29, 2026, Status: verified
   > a producer is exempt from the requirements and prohibitions of this section in any calendar year in which: (en)
39. maine.gov: epr (https://www.maine.gov/dep/waste/recycle/epr.html), Retrieved: September 29, 2026, Status: verified
   > In July 2021, the Legislature passed a law establishing Maine’s Stewardship Program for Packaging, 38 M.R.S. § 2146. (en)
40. legislature.maine.gov: title38sec2146 (https://legislature.maine.gov/statutes/38/title38sec2146.html), Retrieved: September 29, 2026, Status: verified
   > The department shall administer and enforce this section and shall adopt rules as necessary to implement, administer and enforce this section. (en)
41. maine.gov: epr (https://www.maine.gov/dep/waste/recycle/epr.html), Retrieved: September 29, 2026, Status: verified
   > Maine DEP to Revise Request for Proposals for Stewardship Organization. (September 11, 2026) (en)
42. maine.gov: epr (https://www.maine.gov/dep/waste/recycle/epr.html), Retrieved: September 29, 2026, Status: verified
   > Within 90 days of the SO making a registration mechanism available, producers must register with the SO. (en)
43. legislature.maine.gov: title38sec2146 (https://legislature.maine.gov/statutes/38/title38sec2146.html), Retrieved: September 29, 2026, Status: verified
   > The producer realized less than $2,000,000 in total gross revenue during the prior calendar year (en)
44. maine.gov: epr (https://www.maine.gov/dep/waste/recycle/epr.html), Retrieved: September 29, 2026, Status: verified
   > Producers of packaging material will annually report to the SO by May 31. (en)
45. circularactionalliance.org: minnesota (https://circularactionalliance.org/minnesota), Retrieved: September 29, 2026, Status: verified
   > Producers must be a member of a PRO that is registered with MPCA by July 1, 2025. (en)
46. revisor.mn.gov: 115A.1441 (https://www.revisor.mn.gov/statutes/cite/115A.1441), Retrieved: September 29, 2026, Status: verified
   > requirements under sections 115A.144 to 115A.1463 (en)
47. circularactionalliance.org: minnesota (https://circularactionalliance.org/minnesota), Retrieved: September 29, 2026, Status: verified
   > the Minnesota Pollution Control Agency (MPCA) confirmed CAA’s registration to implement the state’s EPR program. (en)
48. web.archive.org (https://web.archive.org/web/20261016213413/https://www.pca.state.mn.us/news-and-stories/mpca-confirms-registration-of-minnesotas-initial-packaging-producer-responsibility-organization), Retrieved: November 5, 2026, Status: verified
   > the MPCA confirmed Circular Action Alliance (CAA) — a 501(c)(3) nonprofit, producer-led organization — as Minnesota’s initial PRO. (en)
49. revisor.mn.gov: 115A.1441 (https://www.revisor.mn.gov/statutes/cite/115A.1441), Retrieved: September 29, 2026, Status: verified
   > introduced less than one ton of covered material into this state (en)
50. revisor.mn.gov: 115A.1443 (https://www.revisor.mn.gov/statutes/cite/115A.1443), Retrieved: September 29, 2026, Status: verified
   > The producer responsibility organization must register with the commissioner by July 1, 2026, and each January 1 thereafter (en)
51. mgaleg.maryland.gov: sb0901E (https://mgaleg.maryland.gov/2025RS/bills/sb/sb0901E.pdf), Retrieved: September 29, 2026, Status: verified
   > A PRODUCER MAY NOT SELL, OFFER FOR SALE, DISTRIBUTE, OR IMPORT FOR SALE OR DISTRIBUTION PACKAGING COVERED MATERIALS FOR USE IN THE STATE UNLESS (en)
52. circularactionalliance.org: maryland (https://circularactionalliance.org/maryland), Retrieved: September 29, 2026, Status: verified
   > In May 2025, Maryland passed SB 901, an Extended Producer Responsibility (en)
53. circularactionalliance.org: maryland (https://circularactionalliance.org/maryland), Retrieved: September 29, 2026, Status: verified
   > Maryland Department of the Environment a list of producers, brands and material type information. (en)
54. circularactionalliance.org: maryland (https://circularactionalliance.org/maryland), Retrieved: September 29, 2026, Status: verified
   > serve as the single nonprofit PRO on the State Producer Responsibility Advisory Council (en)
55. circularactionalliance.org: maryland (https://circularactionalliance.org/maryland), Retrieved: September 29, 2026, Status: verified
   > Producers must register with CAA by May 31, 2026 (en)
56. mgaleg.maryland.gov: sb0901E (https://mgaleg.maryland.gov/2025RS/bills/sb/sb0901E.pdf), Retrieved: September 29, 2026, Status: verified
   > INTRODUCED LESS THAN 1 TON OF COVERED MATERIAL INTO THE STATE (en)
57. gov.uk: check if you must comply with epr for packaging 2 (https://www.gov.uk/guidance/check-if-you-must-comply-with-epr-for-packaging--2), Retrieved: September 29, 2026, Status: verified
   > you supplied or imported more than 25 tonnes of packaging in the UK in the previous year (en)
58. gov.uk (https://www.gov.uk/guidance/how-to-comply-with-packaging-recycling-obligations-as-a-large-producer), Retrieved: November 3, 2026, Status: verified
   > go to schedule 5 of the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (as amended) (en)
59. gov.uk: epr for packaging what you must do as a small producer (https://www.gov.uk/guidance/epr-for-packaging-what-you-must-do-as-a-small-producer), Retrieved: September 29, 2026, Status: verified
   > Each of the 4 nations of the United Kingdom has its own regulator. You’ll be reporting to and monitored by the regulator for your nation. (en)
60. gov.uk: epr for packaging what you must do as a small producer (https://www.gov.uk/guidance/epr-for-packaging-what-you-must-do-as-a-small-producer), Retrieved: September 29, 2026, Status: verified
   > Compliance schemes are third parties that help organisations meet the EPR for packaging requirements. (en)
61. gov.uk: epr for packaging what you must do as a small producer (https://www.gov.uk/guidance/epr-for-packaging-what-you-must-do-as-a-small-producer), Retrieved: November 3, 2026, Status: verified
   > the fee is: £1,303 if you register directly with your environmental regulator £696 if you register through a compliance scheme (en)
62. gov.uk (https://www.gov.uk/guidance/packaging-data-check-reporting-periods-and-submission-deadlines), Retrieved: November 3, 2026, Status: verified
   > 1 January to 30 June 2026 1 October 2026 (en)
63. fostplus.be: become a fost plus member (https://www.fostplus.be/en/members/become-a-fost-plus-member), Retrieved: September 29, 2026, Status: verified
   > Does your company put household packaging on the market? Then you have an obligation to report on this packaging to the government. (en)
64. valipac.academy: belgian legislative framework (https://valipac.academy/en/modules/gaining-a-better-understanding-of-the-legislation/belgian-legislative-framework/), Retrieved: September 29, 2026, Status: verified
   > The new version of the Cooperation Agreement has been in force since 5 March 2020. (en)
65. valipac.academy: belgian legislative framework (https://valipac.academy/en/modules/gaining-a-better-understanding-of-the-legislation/belgian-legislative-framework/), Retrieved: September 29, 2026, Status: verified
   > The Interregional Packaging Commission is responsible for the enforcement of the Cooperation Agreement. (en)
66. fostplus.be (https://www.fostplus.be/en/blog/ppwr-insights-8-mandatory-registration-in-producer-register-fost-plus-handles-it-for-you), Retrieved: September 29, 2026, Status: verified
   > This representative must (1) be established in Belgium and (2) be registered with EPRiBEL. (en)
67. fostplus.be (https://www.fostplus.be/en/blog/ppwr-insights-8-mandatory-registration-in-producer-register-fost-plus-handles-it-for-you), Retrieved: September 29, 2026, Status: verified
   > Companies that are not members of Fost Plus or another recognised EPR organisation can register directly through EPRiBEL (en)
68. fostplus.be: become a fost plus member (https://www.fostplus.be/en/members/become-a-fost-plus-member), Retrieved: September 29, 2026, Status: verified
   > companies that put at least 300 tonnes of single-use packaging on the market annually (en)
69. fostplus.be: declaration (https://www.fostplus.be/en/members/declaration), Retrieved: September 29, 2026, Status: verified
   > Exceptionally, you can still amend your 2025 declaration until 15 September this year. (en)

## Cite this page

Instica, “California extended producer responsibility”, https://instica.com/epr/california, last verified 2026-11-05, dataset v1-281284b7e7c1, CC-BY-4.0.

- Canonical URL: https://instica.com/epr/california
- Last verified: November 5, 2026
- Last changed: November 3, 2026
- Dataset version: v1-281284b7e7c1
- Licence: Reuse is allowed under CC-BY-4.0 with credit to Instica and a link to this page.
- Machine-readable versions: https://instica.com/epr/california.md · https://instica.com/epr/california.json