# California vs Washington EPR: Rules Compared

Last verified: November 5, 2026 · https://instica.com/epr/compare/california-vs-washington

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

California and Washington both run packaging EPR, but the rules differ. California exempts only producers below the lower revenue floor, $1,000,000 against $5,000,000 in Washington. Both require producers to register. Every figure below links to its primary source. Instica measures, estimates and prepares; the customer signs and submits.

<a id="glance"></a>

## California and Washington side by side

2 of 9 rows have a verified figure on each side of California and Washington; a cell reads “not yet published” when a side has none, and an exemption row reads “none recorded; see thresholds” when no exemption is on record.

<a id="glance-table"></a>**California and Washington: the measures both programmes publish**

| Measure | California | Washington | Stricter |
| --- | --- | --- | --- |
| Registration duty | Required | Required | Same |
| Producer organisation | one producer responsibility organisation | one producer responsibility organisation | Not comparable |
| Lowest revenue exemption | $1,000,000 | $5,000,000 | California |
| Lowest weight exemption | none recorded; see thresholds | 907.2 kg | Not comparable |
| First annual report date | not yet published | May 31 | Not comparable |
| Published penalties | 1 published | 1 published | Not comparable |
| Report file | csv | csv | Not comparable |
| Paper fee, cheapest matched rate | 0.4 cents per pound | not yet published | Not comparable |
| Plastic fee, cheapest matched rate | 2.5 cents per pound | not yet published | Not comparable |

<a id="calc-revenue"></a>The lowest revenue exemption is $1,000,000 in California and $5,000,000 in Washington. California therefore reaches smaller sellers: a business with revenue between the two lines is exempt in Washington but still in scope in California.

<a id="calc-registration"></a>Both programmes require a producer to register, in California and in Washington.

<a id="programme"></a>

## Who runs the programme in California and Washington

Who collects and who the producer files with, in California and then Washington.

<a id="programme-table"></a>**California and Washington: how each programme is set up**

| Aspect | California | Washington |
| --- | --- | --- |
| Regime | California SB 54, Plastic Pollution Prevention and Packaging Producer Responsibility Act (Public Resources Code, Division 30, Part 3, Chapter 3.1) | Washington Recycling Reform Act, chapter 70A.208 RCW |
| Regulator | CalRecycle (Department of Resources Recycling and Recovery), through its PEPRS portal | Washington State Department of Ecology |
| Producers obligated | Yes | Yes |
| Registration | Required, PEPRS (CalRecycle Packaging Extended Producer Responsibility System) | Required, Producer registers with a PRO; the PRO registers with Ecology |
| Producer organisation | one producer responsibility organisation: Circular Action Alliance; membership required | one producer responsibility organisation: Circular Action Alliance; membership required |
| Transfer of responsibility | Not allowed | not yet published |
| Revenue counted as | gross revenue inside the jurisdiction, USD, calendar year | worldwide gross revenue, USD, prior fiscal year |
| Who counts as the producer | other: manufacturer or brand owner, brand licensee, first distributor; primary: manufacturer or brand owner, brand licensee, first distributor; secondary: manufacturer or brand owner, brand licensee, first distributor; service: manufacturer or brand owner, brand licensee, first distributor; shipping: manufacturer or brand owner, brand licensee, first distributor; tertiary: manufacturer or brand owner, brand licensee, first distributor | primary: manufacturer, brand licensee, brand owner, importer |

> **Not yet published**: Not yet published for Washington: the rules on transferring responsibility. Reason: No transfer or delegation rule was found in the definition read. The PRO section allows a producer to designate a PRO, which is membership, not a transfer.

Both programmes organise producer responsibility the same way: one producer responsibility organisation. The practical differences between California and Washington therefore sit in thresholds, fees, dates and report formats rather than in whom a producer deals with.

<a id="scope"></a>

## What California and Washington cover, side by side

Each row below is one published feature of the two programmes; a cell reads “not yet published” when California or Washington has no verified entry for it in the dataset.

<a id="scope-table"></a>**Scope, producer duties, categories, labelling and targets, California and Washington**

| Aspect | California | Washington |
| --- | --- | --- |
| Materials covered | single use packaging, plastic single use food service ware | packaging, paper products |
| Product classes covered | primary packaging, secondary packaging, tertiary packaging, packaging components and ancillary elements | packaging, paper |
| Excluded from scope | medical products and drugs, animal medicines, infant formula, medical food, fifra products, dangerous goods plastic containers, hazcom hazardous or flammable products, beverage containers subject to crv, long term product protection 5 years, architectural paint program packaging, agricultural commodity packaged on site | exempt materials |
| Sales channels addressed | retail, wholesale, remote offering, online | physical retail, remote sale, other distribution |
| Producer duty: primary packaging | manufacturer_brand_owner; licensee; first_distributor | manufacturer; licensee; brand_owner; importer |
| Producer duty: secondary packaging | manufacturer_brand_owner; licensee; first_distributor | not yet published |
| Producer duty: tertiary packaging | manufacturer_brand_owner; licensee; first_distributor | not yet published |
| Producer duty: shipping packaging | manufacturer_brand_owner; licensee; first_distributor | not yet published |
| Producer duty: service packaging | manufacturer_brand_owner; licensee; first_distributor | not yet published |
| Producer duty: other packaging | manufacturer_brand_owner; licensee; first_distributor | not yet published |
| Published targets | plastic_source_reduction 10 by 2027-01-01; plastic_source_reduction 20 by 2030-01-01; plastic_source_reduction 25 by 2032-01-01; plastic_recycling_rate 30 by 2028-01-01; plastic_recycling_rate 40 by 2030-01-01; plastic_recycling_rate 65 by 2032-01-01; recyclable_or_compostable_share 100 by 2032-01-01 | not yet published |
| Exemption 1 | 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. (application needed) | A de minimis producer is under one ton, or under the global revenue limit, or an agricultural employer within limits. |
| Exemption 2 | A person who produces, harvests and packages an agricultural commodity on the site where it was grown or raised is not a producer. | Registered 501(c)(3) and 501(c)(4) organizations are excluded from the producer definition. |
| Exemption 3 | Beverage containers subject to the California Beverage Container Recycling and Litter Reduction Act are not covered material. | not yet published |
| Exemption 4 | 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. (application needed) | not yet published |

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

## Thresholds and exemptions in California and Washington

Every verified threshold California and Washington publish, as each states it.

<a id="thresholds-table"></a>**Verified thresholds in California and Washington**

| Place | Measure | Amount | Effect | Basis as published |
| --- | --- | ---: | --- | --- |
| California | revenue | $1,000,000 | exempt below | gross annual sales in California, most recent calendar year |
| Washington | packaging tonnage | 1 short ton | exempt below | covered materials introduced, most recent fiscal year |
| Washington | revenue | $5,000,000 | exempt below | global gross revenue, prior fiscal year |

<a id="a-exemption-small-producer"></a>California exemption: 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. It must be applied for.

<a id="a-exemption-agricultural-commodity-on-site"></a>California exemption: A person who produces, harvests and packages an agricultural commodity on the site where it was grown or raised is not a producer. It does not have to be applied for.

<a id="a-exemption-crv-beverage-containers"></a>California exemption: Beverage containers subject to the California Beverage Container Recycling and Litter Reduction Act are not covered material. It does not have to be applied for.

<a id="a-exemption-high-recycling-rate-material"></a>California exemption: 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. It must be applied for.

<a id="b-exemption-de-minimis-producer"></a>Washington exemption: A de minimis producer is under one ton, or under the global revenue limit, or an agricultural employer within limits. It does not have to be applied for.

<a id="b-exemption-nonprofits"></a>Washington exemption: Registered 501(c)(3) and 501(c)(4) organizations are excluded from the producer definition. It does not have to be applied for.

Read the basis column first: the same amount can exempt a producer in one programme and only simplify its report in another.

The lowest revenue exemption is $1,000,000 in California and $5,000,000 in Washington. California therefore reaches smaller sellers: a business with revenue between the two lines is exempt in Washington but still in scope in California.

<a id="rates"></a>

## Fees per kilogram for shared materials

California publishes per-kilogram rates in the dataset; Washington does not. The rows therefore show California only. Until both sides publish per-kilogram rates for the same material class, a fee comparison between California and Washington would mean inventing a figure, and this page does not do that.

> **Not yet published**: Washington: no verified per-kilogram fee schedule is in the dataset yet.

<a id="a-fee-source"></a>California: the 2026 fee schedule of Circular Action Alliance (California PRO), early fee, effective January 1, 2026, is the source of the per-kilogram rates used on this page.

<a id="a-rate-paper-fiber"></a>California 2026: the category “Paper/Fiber” is published at 0.4 cents per pound.

<a id="a-rate-plastic-flexible"></a>California 2026: the category “Plastic - Flexible” is published at 2.5 cents per pound.

<a id="a-rate-glass-ceramics"></a>California 2026: the category “Glass and Ceramics” is published at 0.3 cents per pound.

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

## Deadlines in California and Washington

Each verified date, with the period it covers when one is given.

<a id="deadlines-table"></a>**Verified deadlines in California and Washington**

| Place | Kind | Date | Covers |
| --- | --- | --- | --- |
| California | registration | January 1, 2027 | not yet published |
| California | taxonomy update | January 1, 2027 | not yet published |
| Washington | other | March 1, 2026 | not yet published |
| Washington | report | May 31, 2026 | not yet published |
| Washington | registration | July 1, 2026 | not yet published |
| Washington | other | October 1, 2028 | not yet published |
| Washington | other | March 1, 2029 | not yet published |
| Washington | other | January 1, 2030 | not yet published |
| Washington | payment | February 15, 2031 | not yet published |
| Washington | payment | February 15, 2032 | not yet published |

> **Not yet published**: Not yet published for California: the annual producer data report date. Reason: The calendar due date for the annual producer report is set by CAA or CalRecycle in its reporting calendar and was not found in a published source.

<a id="penalties"></a>

## Penalties in California and Washington

What each side has published; a side without an amount says so.

<a id="a-penalty-0"></a>California penalty for failure to comply with the chapter or its regulations: up to $50,000 per day per violation.

<a id="b-penalty-0"></a>Washington penalty for producer violating chapter 70A.208 RCW: up to $1,000 per day.

<a id="formats"></a>

## Report formats in California and Washington

How the report file for California compares with the one for Washington.

<a id="formats-table"></a>**Report file layouts for California and Washington**

| Aspect | California | Washington |
| --- | --- | --- |
| Layout | California SB 54 producer data by covered material category 2026-09-29 (built from PRC 42052(a)(1) and CalRecycle guidance of 4 August 2026) | Washington interim producer supply report by material class 2026-09-29 (interim, built from CAA guidance) |
| Recipient | Circular Action Alliance (PRO) or CalRecycle through PEPRS for self-reporting producers | Circular Action Alliance (Washington PRO) |
| How it is submitted | CAA producer portal, or CalRecycle PEPRS when the producer reports directly. The customer signs in and submits. | CAA producer portal. The customer signs in and submits. |
| File type | csv | csv |
| Encoding | utf-8 | utf-8 |
| Delimiter | , | , |
| Decimal separator | . |
| Columns | 5 | 4 |
| Required columns | 5 of 5 | 4 of 4 |
| Weight unit | lb | lb |
| Period basis | calendar year | calendar year |

> **Not yet published**: California: the programme’s own report specification is not yet published. Reason: CAA publishes a 2026 Annual Supply Report preparation workbook (2025 data year) with 95 reporting categories, weights in pounds to two decimals and plastic-component counts, but the workbook cannot be uploaded; the report is entered on the CAA Producer Portal. Instica's file is its own working layout and does not yet reproduce those categories. The layout above is Instica’s working layout.

> **Not yet published**: Washington: the programme’s own report specification is not yet published. Reason: The PRO says Washington material reporting categories are not yet known, and the draft plan is not expected until 2028. Only the simplified interim reporting exists, and it is portal-only. The layout above is Instica’s working layout.

The two layouts share a file type and a delimiter, but each programme names its own columns and categories, so one file cannot be sent to both programmes. Each report is built from the same underlying measurements and exported separately.

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## Which to plan for first, California or Washington

Check the exemption thresholds before anything else. California reaches smaller sellers than Washington, so a seller that is exempt in Washington may still have to register in California.

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

## Questions about comparing these two programmes

### <a id="q1"></a>Is California or Washington stricter on packaging EPR?

California exempts only producers below the lower revenue floor, $1,000,000 against $5,000,000 in Washington. Both require producers to register.

### <a id="q2"></a>Do I register in both California and Washington?

California requires producers to register. Washington requires producers to register.

### <a id="q3"></a>How do the fees per kilogram compare in California and Washington?

The dataset does not hold per-kilogram rates for the same material class on both sides, so this page does not compare fees.

### <a id="q4"></a>Which deadline comes first, California or Washington?

The dataset does not hold a verified annual report date on both sides, so this page does not say which comes first.

<a id="paa"></a>

### <a id="paa-1"></a>Which states have passed EPR laws?

California: at the primary packaging level the producer hierarchy names the manufacturer or brand owner, brand licensee and first distributor (2023). Washington: at the primary packaging level the producer hierarchy names the manufacturer, brand licensee, brand owner and importer (2025).

### <a id="paa-2"></a>Does CA actually recycle?

California: the packaging rules sit in California SB 54, Plastic Pollution Prevention and Packaging Producer Responsibility Act (Public Resources Code, Division 30, Part 3, Chapter 3.1). Washington: the packaging rules sit in Washington Recycling Reform Act, chapter 70A.208 RCW. California: the regulator is CalRecycle (Department of Resources Recycling and Recovery), through its PEPRS portal.

### <a id="paa-3"></a>What can you recycle in Washington state?

Washington: the packaging rules sit in Washington Recycling Reform Act, chapter 70A.208 RCW. California: the regulator is CalRecycle (Department of Resources Recycling and Recovery), through its PEPRS portal. Washington: the regulator is Washington State Department of Ecology. California places an obligation on packaging producers.

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

## How these figures are made

> **Estimate**: Instica measures, estimates and prepares. Every figure on this page is read from a sourced record or computed from one, and each carries its data quality. Converted amounts are approximate and name the exchange rate used. The customer signs and submits each report; Instica never stores regulator login details and never files on your behalf. This page is general information about published rules; confirm your own position with a qualified adviser.

<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.

- <a id="a-regime"></a>California: the packaging rules sit in California SB 54, Plastic Pollution Prevention and Packaging Producer Responsibility Act (Public Resources Code, Division 30, Part 3, Chapter 3.1). [#a-regime](#a-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
- <a id="a-regulator"></a>California: the regulator is CalRecycle (Department of Resources Recycling and Recovery), through its PEPRS portal. [#a-regulator](#a-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
- <a id="a-obligated"></a>California places an obligation on packaging producers. [#a-obligated](#a-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
- <a id="a-registration"></a>California: producers must register through PEPRS (CalRecycle Packaging Extended Producer Responsibility System). [#a-registration](#a-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.
- <a id="a-organisation"></a>California organises producer responsibility through a single producer responsibility organisation: Circular Action Alliance; membership is required. [#a-organisation](#a-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.
- <a id="a-transfer"></a>California does not allow a producer’s obligation to be transferred to another party. [#a-transfer](#a-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.
- <a id="a-revenue-scope"></a>California measures revenue as gross revenue inside the jurisdiction in USD, over the calendar year. [#a-revenue-scope](#a-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.
- <a id="a-hierarchy-other"></a>California: at the other packaging level the producer hierarchy names the manufacturer or brand owner, brand licensee and first distributor (2023). [#a-hierarchy-other](#a-hierarchy-other)
  Value: manufacturer_brand_owner > licensee > first_distributor · 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
- <a id="a-hierarchy-primary"></a>California: at the primary packaging level the producer hierarchy names the manufacturer or brand owner, brand licensee and first distributor (2023). [#a-hierarchy-primary](#a-hierarchy-primary)
  Value: manufacturer_brand_owner > licensee > first_distributor · 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
- <a id="a-hierarchy-secondary"></a>California: at the secondary packaging level the producer hierarchy names the manufacturer or brand owner, brand licensee and first distributor (2023). [#a-hierarchy-secondary](#a-hierarchy-secondary)
  Value: manufacturer_brand_owner > licensee > first_distributor · 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
- <a id="a-hierarchy-service"></a>California: at the service packaging level the producer hierarchy names the manufacturer or brand owner, brand licensee and first distributor (2023). [#a-hierarchy-service](#a-hierarchy-service)
  Value: manufacturer_brand_owner > licensee > first_distributor · 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
- <a id="a-hierarchy-shipping"></a>California: at the shipping packaging level the producer hierarchy names the manufacturer or brand owner, brand licensee and first distributor (2023). [#a-hierarchy-shipping](#a-hierarchy-shipping)
  Value: manufacturer_brand_owner > licensee > first_distributor · 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
- <a id="a-hierarchy-tertiary"></a>California: at the tertiary packaging level the producer hierarchy names the manufacturer or brand owner, brand licensee and first distributor (2023). [#a-hierarchy-tertiary](#a-hierarchy-tertiary)
  Value: manufacturer_brand_owner > licensee > first_distributor · 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
- <a id="a-threshold-small-producer-gross-annual-sales"></a>California threshold on revenue: $1,000,000; effect: exempt below the threshold. [#a-threshold-small-producer-gross-annual-sales](#a-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.
- California exemption: 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. It must be applied for. [#a-exemption-small-producer](#a-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.
- California exemption: A person who produces, harvests and packages an agricultural commodity on the site where it was grown or raised is not a producer. It does not have to be applied for. [#a-exemption-agricultural-commodity-on-site](#a-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.
- California exemption: Beverage containers subject to the California Beverage Container Recycling and Litter Reduction Act are not covered material. It does not have to be applied for. [#a-exemption-crv-beverage-containers](#a-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)).
- California exemption: 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. It must be applied for. [#a-exemption-high-recycling-rate-material](#a-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
- <a id="a-deadline-join-pro-or-be-approved"></a>California: registration date January 1, 2027. [#a-deadline-join-pro-or-be-approved](#a-deadline-join-pro-or-be-approved)
  Value: January 1, 2027 · Source: https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=PRC&sectionNum=42051 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: upon approval of a plan pursuant to Section 42063, or commencing January 1, 2027, whichever is sooner
- <a id="a-deadline-cmc-list-update"></a>California: taxonomy update date January 1, 2027. [#a-deadline-cmc-list-update](#a-deadline-cmc-list-update)
  Value: January 1, 2027 · Source: https://calrecycle.ca.gov/packaging/packaging-epr/ · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: This updated information will inform the next update to the Covered Material Categories List, which will be published by January 1, 2027.
- California penalty for failure to comply with the chapter or its regulations: up to $50,000 per day per violation. [#a-penalty-0](#a-penalty-0)
  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
- <a id="a-scope-materials"></a>California: materials covered is single use packaging, plastic single use food service ware. [#a-scope-materials](#a-scope-materials)
  Value: single_use_packaging,plastic_single_use_food_service_ware · Source: https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=PRC&sectionNum=42041 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: the sale of covered materials shall be deemed to occur in the state if the covered materials are delivered to the purchaser in the state
- <a id="a-scope-products"></a>California: product classes covered is primary packaging, secondary packaging, tertiary packaging, packaging components and ancillary elements. [#a-scope-products](#a-scope-products)
  Value: primary_packaging,secondary_packaging,tertiary_packaging,packaging_components_and_ancillary_elements · Source: https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=PRC&sectionNum=42041 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: the sale of covered materials shall be deemed to occur in the state if the covered materials are delivered to the purchaser in the state
- <a id="a-scope-excluded"></a>California: excluded from scope is medical products and drugs, animal medicines, infant formula, medical food, fifra products, dangerous goods plastic containers, hazcom hazardous or flammable products, beverage containers subject to crv, long term product protection 5 years, architectural paint program packaging, agricultural commodity packaged on site. [#a-scope-excluded](#a-scope-excluded)
  Value: medical_products_and_drugs,animal_medicines,infant_formula,medical_food,fifra_products,dangerous_goods_plastic_containers,hazcom_hazardous_or_flammable_products,beverage_containers_subject_to_crv,long_term_product_protection_5_years,architectural_paint_program_packaging,agricultural_commodity_packaged_on_site · Source: https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=PRC&sectionNum=42041 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: the sale of covered materials shall be deemed to occur in the state if the covered materials are delivered to the purchaser in the state
- <a id="a-scope-channels"></a>California: sales channels addressed is retail, wholesale, remote offering, online. [#a-scope-channels](#a-scope-channels)
  Value: retail,wholesale,remote_offering,online · Source: https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=PRC&sectionNum=42041 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: the sale of covered materials shall be deemed to occur in the state if the covered materials are delivered to the purchaser in the state
- <a id="a-scope-ph-primary"></a>California: producer duty: primary packaging is manufacturer_brand_owner; licensee; first_distributor. [#a-scope-ph-primary](#a-scope-ph-primary)
  Value: manufacturer or brand owner, licensee, and first distributor · 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
- <a id="a-scope-ph-secondary"></a>California: producer duty: secondary packaging is manufacturer_brand_owner; licensee; first_distributor. [#a-scope-ph-secondary](#a-scope-ph-secondary)
  Value: manufacturer or brand owner, licensee, and first distributor · 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
- <a id="a-scope-ph-tertiary"></a>California: producer duty: tertiary packaging is manufacturer_brand_owner; licensee; first_distributor. [#a-scope-ph-tertiary](#a-scope-ph-tertiary)
  Value: manufacturer or brand owner, licensee, and first distributor · 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
- <a id="a-scope-ph-shipping"></a>California: producer duty: shipping packaging is manufacturer_brand_owner; licensee; first_distributor. [#a-scope-ph-shipping](#a-scope-ph-shipping)
  Value: manufacturer or brand owner, licensee, and first distributor · 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
- <a id="a-scope-ph-service"></a>California: producer duty: service packaging is manufacturer_brand_owner; licensee; first_distributor. [#a-scope-ph-service](#a-scope-ph-service)
  Value: manufacturer or brand owner, licensee, and first distributor · 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
- <a id="a-scope-ph-other"></a>California: producer duty: other packaging is manufacturer_brand_owner; licensee; first_distributor. [#a-scope-ph-other](#a-scope-ph-other)
  Value: manufacturer or brand owner, licensee, and first distributor · 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
- <a id="a-scope-targets"></a>California: published targets is plastic_source_reduction 10 by 2027-01-01; plastic_source_reduction 20 by 2030-01-01; plastic_source_reduction 25 by 2032-01-01; plastic_recycling_rate 30 by 2028-01-01; plastic_recycling_rate 40 by 2030-01-01; plastic_recycling_rate 65 by 2032-01-01; recyclable_or_compostable_share 100 by 2032-01-01. [#a-scope-targets](#a-scope-targets)
  Value: 7 · Source: https://calrecycle.ca.gov/packaging/packaging-epr/producerguidance/ · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: 65% Single-Use Plastic Recycled
- <a id="a-scope-ex1"></a>California: exemption 1 is 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. (application needed). [#a-scope-ex1](#a-scope-ex1)
  Value: 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. · 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.
- <a id="a-scope-ex2"></a>California: exemption 2 is A person who produces, harvests and packages an agricultural commodity on the site where it was grown or raised is not a producer. [#a-scope-ex2](#a-scope-ex2)
  Value: A person who produces, harvests and packages an agricultural commodity on the site where it was grown or raised is not a producer. · 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.
- <a id="a-scope-ex3"></a>California: exemption 3 is Beverage containers subject to the California Beverage Container Recycling and Litter Reduction Act are not covered material. [#a-scope-ex3](#a-scope-ex3)
  Value: Beverage containers subject to the California Beverage Container Recycling and Litter Reduction Act are not covered material. · 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)).
- <a id="a-scope-ex4"></a>California: exemption 4 is 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. (application needed). [#a-scope-ex4](#a-scope-ex4)
  Value: 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. · 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
- <a id="b-regime"></a>Washington: the packaging rules sit in Washington Recycling Reform Act, chapter 70A.208 RCW. [#b-regime](#b-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
- <a id="b-regulator"></a>Washington: the regulator is Washington State Department of Ecology. [#b-regulator](#b-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.
- <a id="b-obligated"></a>Washington places an obligation on packaging producers. [#b-obligated](#b-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
- <a id="b-registration"></a>Washington: producers must register through Producer registers with a PRO; the PRO registers with Ecology. [#b-registration](#b-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.
- <a id="b-organisation"></a>Washington organises producer responsibility through a single producer responsibility organisation: Circular Action Alliance; membership is required. [#b-organisation](#b-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.
- <a id="b-revenue-scope"></a>Washington measures revenue as worldwide gross revenue in USD, over the prior fiscal year. [#b-revenue-scope](#b-revenue-scope)
  Value: global_gross_revenue · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: Has a global gross revenue, not including on-premises alcohol sales, for the prior fiscal year of
- <a id="b-hierarchy-primary"></a>Washington: at the primary packaging level the producer hierarchy names the manufacturer, brand licensee, brand owner and importer (2025). [#b-hierarchy-primary](#b-hierarchy-primary)
  Value: manufacturer > licensee > brand_owner > importer · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: the producer is the person that manufactures the item
- <a id="b-threshold-de-minimis-tonnage"></a>Washington threshold on tonnage: 1 short ton; effect: exempt below the threshold. [#b-threshold-de-minimis-tonnage](#b-threshold-de-minimis-tonnage)
  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
- <a id="b-threshold-de-minimis-revenue"></a>Washington threshold on revenue: $5,000,000; effect: exempt below the threshold. [#b-threshold-de-minimis-revenue](#b-threshold-de-minimis-revenue)
  Value: $5,000,000 · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: Until January 1, 2031, less than $5,000,000
- Washington exemption: A de minimis producer is under one ton, or under the global revenue limit, or an agricultural employer within limits. It does not have to be applied for. [#b-exemption-de-minimis-producer](#b-exemption-de-minimis-producer)
  Value: de_minimis_producer · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: "De minimis producer" means a producer that
- Washington exemption: Registered 501(c)(3) and 501(c)(4) organizations are excluded from the producer definition. It does not have to be applied for. [#b-exemption-nonprofits](#b-exemption-nonprofits)
  Value: nonprofits · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: Registered 501(c)(3) charitable organizations and 501(c)(4) social welfare organizations
- <a id="b-deadline-pro-registers-with-ecology"></a>Washington: other date March 1, 2026. [#b-deadline-pro-registers-with-ecology](#b-deadline-pro-registers-with-ecology)
  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.
- <a id="b-deadline-simplified-report-2026"></a>Washington: report date May 31, 2026. [#b-deadline-simplified-report-2026](#b-deadline-simplified-report-2026)
  Value: May 31, 2026 · Source: https://circularactionalliance.org/washington · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: By May 31, 2026 Reporting (Interim State Addendum Signed & Simplified Reporting)
- <a id="b-deadline-producer-pro-membership"></a>Washington: registration date July 1, 2026. [#b-deadline-producer-pro-membership](#b-deadline-producer-pro-membership)
  Value: July 1, 2026 · 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
- <a id="b-deadline-plan-due"></a>Washington: other date October 1, 2028. [#b-deadline-plan-due](#b-deadline-plan-due)
  Value: October 1, 2028 · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: By October 1, 2028, and every five years thereafter, submit a plan that meets the requirements of this chapter
- <a id="b-deadline-non-member-sales-ban"></a>Washington: other date March 1, 2029. [#b-deadline-non-member-sales-ban](#b-deadline-non-member-sales-ban)
  Value: March 1, 2029 · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: Beginning March 1, 2029, a producer that is not a member in good standing with a registered producer responsibility organization
- <a id="b-deadline-program-implementation"></a>Washington: other date January 1, 2030. [#b-deadline-program-implementation](#b-deadline-program-implementation)
  Value: January 1, 2030 · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: By January 1, 2030, or within six months of plan approval, whichever is later, implement the plan approved by the department
- <a id="b-deadline-net-cost-75"></a>Washington: payment date February 15, 2031. [#b-deadline-net-cost-75](#b-deadline-net-cost-75)
  Value: February 15, 2031 · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: No less than 75 percent of the net costs by February 15, 2031
- <a id="b-deadline-net-cost-90"></a>Washington: payment date February 15, 2032. [#b-deadline-net-cost-90](#b-deadline-net-cost-90)
  Value: February 15, 2032 · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: No less than 90 percent of the net costs by February 15, 2032, and each year thereafter
- Washington penalty for producer violating chapter 70A.208 RCW: up to $1,000 per day. [#b-penalty-0](#b-penalty-0)
  Value: $1,000 · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: civil penalty of up to $1,000 per violation per day on any producer who violates this chapter
- <a id="b-scope-materials"></a>Washington: materials covered is packaging, paper products. [#b-scope-materials](#b-scope-materials)
  Value: packaging,paper_products · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: "Covered material" means packaging and paper products introduced into the state.
- <a id="b-scope-products"></a>Washington: product classes covered is packaging, paper. [#b-scope-products](#b-scope-products)
  Value: packaging,paper · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: "Covered material" means packaging and paper products introduced into the state.
- <a id="b-scope-excluded"></a>Washington: excluded from scope is exempt materials. [#b-scope-excluded](#b-scope-excluded)
  Value: exempt_materials · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: "Covered material" means packaging and paper products introduced into the state.
- <a id="b-scope-channels"></a>Washington: sales channels addressed is physical retail, remote sale, other distribution. [#b-scope-channels](#b-scope-channels)
  Value: physical_retail,remote_sale,other_distribution · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: "Covered material" means packaging and paper products introduced into the state.
- <a id="b-scope-ph-primary"></a>Washington: producer duty: primary packaging is manufacturer; licensee; brand_owner; importer. [#b-scope-ph-primary](#b-scope-ph-primary)
  Value: manufacturer, licensee, brand owner, and importer · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: the producer is the person that manufactures the item
- <a id="b-scope-ex1"></a>Washington: exemption 1 is A de minimis producer is under one ton, or under the global revenue limit, or an agricultural employer within limits. [#b-scope-ex1](#b-scope-ex1)
  Value: A de minimis producer is under one ton, or under the global revenue limit, or an agricultural employer within limits. · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: "De minimis producer" means a producer that
- <a id="b-scope-ex2"></a>Washington: exemption 2 is Registered 501(c)(3) and 501(c)(4) organizations are excluded from the producer definition. [#b-scope-ex2](#b-scope-ex2)
  Value: Registered 501(c)(3) and 501(c)(4) organizations are excluded from the producer definition. · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: Registered 501(c)(3) charitable organizations and 501(c)(4) social welfare organizations
- The lowest revenue exemption is $1,000,000 in California and $5,000,000 in Washington. California therefore reaches smaller sellers: a business with revenue between the two lines is exempt in Washington but still in scope in California. [#calc-revenue](#calc-revenue)
  Value: US-CA · 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.
- Both programmes require a producer to register, in California and in Washington. [#calc-registration](#calc-registration)
  Value: same · 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.
- California: the 2026 fee schedule of Circular Action Alliance (California PRO), early fee, effective January 1, 2026, is the source of the per-kilogram rates used on this page. [#a-fee-source](#a-fee-source)
  Value: CAA California 2026 Early Fee Schedule · Source: https://circularactionalliance.org/s/CA-2026-Early-Fee-Schedule.pdf · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: 2026 California Early Fee Schedule Fees for Program Year 2026
- California 2026: the category “Paper/Fiber” is published at 0.4 cents per pound. [#a-rate-paper-fiber](#a-rate-paper-fiber)
  Value: 0.4 cents_per_lb · Source: https://circularactionalliance.org/s/CA-2026-Early-Fee-Schedule.pdf · Retrieved: October 7, 2026 · Status: verified
  Verbatim quote: Paper/Fiber $0.004 /lb
- California 2026: the category “Plastic - Flexible” is published at 2.5 cents per pound. [#a-rate-plastic-flexible](#a-rate-plastic-flexible)
  Value: 2.5 cents_per_lb · Source: https://circularactionalliance.org/s/CA-2026-Early-Fee-Schedule.pdf · Retrieved: October 7, 2026 · Status: verified
  Verbatim quote: Plastic - Flexible $0.025 /lb
- California 2026: the category “Glass and Ceramics” is published at 0.3 cents per pound. [#a-rate-glass-ceramics](#a-rate-glass-ceramics)
  Value: 0.3 cents_per_lb · Source: https://circularactionalliance.org/s/CA-2026-Early-Fee-Schedule.pdf · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Glass and Ceramics $0.003 /lb

## Related pages

### Part of

- [California extended producer responsibility](https://instica.com/epr/california)

### Explore packaging EPR

- [United States packaging EPR: 7 jurisdictions](https://instica.com/epr/united-states)

### More for this jurisdiction

- [Washington EPR](https://instica.com/epr/washington)

### Related pages

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- [Colorado vs Manitoba EPR: Rules Compared](https://instica.com/epr/compare/colorado-vs-manitoba)
- [Colorado vs Minnesota EPR: Rules Compared](https://instica.com/epr/compare/colorado-vs-minnesota)
- [Colorado vs New Brunswick EPR: Rules Compared](https://instica.com/epr/compare/colorado-vs-new-brunswick)
- [Colorado vs Nova Scotia EPR: Rules Compared](https://instica.com/epr/compare/colorado-vs-nova-scotia)

## 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
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
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
4. 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.
5. 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.
6. 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.
7. 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.
8. 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
9. calrecycle.ca.gov: exemptionsexclusions (https://calrecycle.ca.gov/packaging/packaging-epr/exemptionsexclusions/), Retrieved: September 29, 2026, Status: verified
   > 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.
10. 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.
11. 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.
12. 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)).
13. 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
14. 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
   > upon approval of a plan pursuant to Section 42063, or commencing January 1, 2027, whichever is sooner
15. calrecycle.ca.gov: packaging epr (https://calrecycle.ca.gov/packaging/packaging-epr/), Retrieved: September 29, 2026, Status: verified
   > This updated information will inform the next update to the Covered Material Categories List, which will be published by January 1, 2027.
16. 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
17. 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 sale of covered materials shall be deemed to occur in the state if the covered materials are delivered to the purchaser in the state
18. calrecycle.ca.gov: producerguidance (https://calrecycle.ca.gov/packaging/packaging-epr/producerguidance/), Retrieved: September 29, 2026, Status: verified
   > 65% Single-Use Plastic Recycled
19. circularactionalliance.org: washington (https://circularactionalliance.org/washington), Retrieved: September 29, 2026, Status: verified
   > required in the Recycling Reform Act
20. 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.
21. 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
22. 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.
23. 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.
24. app.leg.wa.gov: default (https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true), Retrieved: November 3, 2026, Status: verified
   > Has a global gross revenue, not including on-premises alcohol sales, for the prior fiscal year of
25. app.leg.wa.gov: default (https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true), Retrieved: November 3, 2026, Status: verified
   > the producer is the person that manufactures the item
26. 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
27. app.leg.wa.gov: default (https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true), Retrieved: November 3, 2026, Status: verified
   > Until January 1, 2031, less than $5,000,000
28. app.leg.wa.gov: default (https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true), Retrieved: November 3, 2026, Status: verified
   > "De minimis producer" means a producer that
29. app.leg.wa.gov: default (https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true), Retrieved: November 3, 2026, Status: verified
   > Registered 501(c)(3) charitable organizations and 501(c)(4) social welfare organizations
30. 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.
31. circularactionalliance.org: washington (https://circularactionalliance.org/washington), Retrieved: September 29, 2026, Status: verified
   > By May 31, 2026 Reporting (Interim State Addendum Signed & Simplified Reporting)
32. app.leg.wa.gov: default (https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true), Retrieved: November 3, 2026, Status: verified
   > By October 1, 2028, and every five years thereafter, submit a plan that meets the requirements of this chapter
33. app.leg.wa.gov: default (https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true), Retrieved: November 3, 2026, Status: verified
   > Beginning March 1, 2029, a producer that is not a member in good standing with a registered producer responsibility organization
34. app.leg.wa.gov: default (https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true), Retrieved: November 3, 2026, Status: verified
   > By January 1, 2030, or within six months of plan approval, whichever is later, implement the plan approved by the department
35. app.leg.wa.gov: default (https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true), Retrieved: November 3, 2026, Status: verified
   > No less than 75 percent of the net costs by February 15, 2031
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
   > No less than 90 percent of the net costs by February 15, 2032, and each year thereafter
37. app.leg.wa.gov: default (https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true), Retrieved: November 3, 2026, Status: verified
   > civil penalty of up to $1,000 per violation per day on any producer who violates this chapter
38. app.leg.wa.gov: default (https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true), Retrieved: November 3, 2026, Status: verified
   > "Covered material" means packaging and paper products introduced into the state.
39. circularactionalliance.org: CA 2026 Early Fee Schedule (https://circularactionalliance.org/s/CA-2026-Early-Fee-Schedule.pdf), Retrieved: September 29, 2026, Status: verified
   > 2026 California Early Fee Schedule Fees for Program Year 2026
40. circularactionalliance.org: CA 2026 Early Fee Schedule (https://circularactionalliance.org/s/CA-2026-Early-Fee-Schedule.pdf), Retrieved: October 7, 2026, Status: verified
   > Paper/Fiber $0.004 /lb
41. circularactionalliance.org: CA 2026 Early Fee Schedule (https://circularactionalliance.org/s/CA-2026-Early-Fee-Schedule.pdf), Retrieved: October 7, 2026, Status: verified
   > Plastic - Flexible $0.025 /lb
42. circularactionalliance.org: CA 2026 Early Fee Schedule (https://circularactionalliance.org/s/CA-2026-Early-Fee-Schedule.pdf), Retrieved: September 29, 2026, Status: verified
   > Glass and Ceramics $0.003 /lb

## Cite this page

Instica, “California vs Washington EPR: Rules Compared”, https://instica.com/epr/compare/california-vs-washington, last verified 2026-11-05, dataset v1-281284b7e7c1, CC-BY-4.0.

- Canonical URL: https://instica.com/epr/compare/california-vs-washington
- Last verified: November 5, 2026
- Last changed: November 5, 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/compare/california-vs-washington.md · https://instica.com/epr/compare/california-vs-washington.json