Summary:

2026 will be the first year in U.S. history where brands must budget for multiple packaging EPR obligations at once. Oregon and Colorado will issue two fee installments based on 2024 data, California will issue its first early fee based on 2025 data, and Maine will introduce start-up fees. Budgeting effectively means understanding fee drivers, forecasting state-by-state exposure, and planning early to avoid cost surprises. May 31st, 2026 is the reporting deadline for multiple states and can take significant preparation.

Why 2026 Is a Landmark Year for EPR Budgets

The U.S. is entering its first multi-state cycle of packaging EPR programs. For brands selling consumer goods, 2026 will bring:

• Multiple invoices across multiple states
  
• Different data years driving different fee calculations
  
• Inconsistent fee schedules and eco-modulation rules
  
• The first true cost impacts of design decisions made years ago
  

For most companies, EPR will shift from an abstract regulatory concept into a material budget line item — often six or seven figures for mid-sized brands.

This guide outlines how to prepare and the timelines to keep in mind. 

1. Know Which States Will Bill You in 2026

Four states will issue EPR-related invoices in 2026, but each one uses a different data set.

2026 EPR Invoicing Overview (By State)

2. Understand What Actually Drives EPR Fees

EPR fees vary, but every state uses the same basic logic:

A. The packaging materials you use

Each SKU must be broken down into:

• Components (bottle, cap, label, wrapper)
  
• Sub-components (especially in CA: adhesives, layers, closures)
  
• Material types (PET, PP, LDPE, aluminum, paper, glass, multilayer)

Each material has a per-kilogram fee rate. Read more here about how rePurpose’s AI powered packaging database can help you fill any data gaps. 

B. State-specific sales volume

EPR fees are state-specific, so brands must know (or accurately estimate) how many units from each SKU were sold in each of these states. 

If exact state-level data is unavailable, compliant estimation methods must be used. The rePurpose Packaging Sustainability and Compliance Platform can help brands here. 

C. Fee schedules (material-specific rates)

Each state publishes fee schedules assigning $/kg rates to different material categories. 

These fee schedules differ significantly across states.

Eco-modulation is the system states use to reward better packaging design through fee decreases (bonuses) or increases (maluses). Eco-modulation will expand in complexity from 2026–2028 as states refine criteria.

3. How EPR Fees Differ Across States

While this basic structure is consistent, application varies widely by state. For example:

• EPR fees vary widely across states because each program is built around its own recycling infrastructure, material markets, and policy goals. 
• States set different per-kilogram fee rates depending on how easily a material can be collected, sorted, and recycled within that state’s system. This means the same material may be inexpensive in one state but have significantly more costly EPR fees in another. 
• Eco-modulation also differs, with each state applying its own bonuses or penalties based on recyclability, PCR content, or design improvements. 
• Reporting categories aren’t standardized either: some states group materials broadly, while others, like California, require sub-component-level reporting and assign separate fees to multi-layer or hard-to-recycle formats. 
• Certain states introduce early or start-up fees (as California does) creating further variation in how and when costs are assessed.

This means a single package can cost different amounts in different states even with identical volumes.

4. Build Your 2026 EPR Budget by State

Budgeting for 2026 requires brands to plan state by state, because each EPR program uses different data years, fee schedules, timelines, and cost structures. 

Oregon and Colorado will issue two fee installments based on 2024 supply data, while California’s single August invoice will be tied to 2025 data and early-fee rules unique to SB54. Maine will introduce start-up fees later in the year, with final amounts still dependent on its Producer Responsibility Organization chosen. 

For most companies, the challenge isn’t just calculating the fees — it’s managing multiple datasets, sales allocations, and reporting templates simultaneously. 

Step 5: Harmonize your packaging data layer now

One of the biggest expense drivers in 2026, other than the actual EPR fees, will be the time, energy, and resources required to navigate the operational complexity for brands without a harmonized and comprehensive dataset.

Harmonization allows companies to:

• Measure packaging once
  
• Map it to every state’s reporting format
  
• Generate all May 31, 2026 reports automatically
  
• Forecast fee impacts reliably

A platform like rePurpose simplifies this dramatically by harmonizing packaging specifications, mapping one dataset across all seven EPR states, generating fee simulations for each jurisdiction, and exporting every required report for the May 31, 2026 deadline. 

This gives finance, sustainability, and packaging teams a single source of truth for budgeting, forecasting, and mitigating surprises before invoices arrive.

5. What Brands Typically Underestimate in Their 2026 Budgets

Based on our work with hundreds of companies, the biggest blind spots are:

• The cost of missing or incomplete SKU specifications
  
• Lack of sub-component detail for California
  
• The time required to reconcile supplier data
  
• The impact of state-by-state sales allocation
  
• Surprises in the number and complexity of material categories
  
• The emerging cost of recycled-content compliance
  
• The administrative cost of multi-state reporting
  
  

Budgeting for only the fee total is not enough — data preparation is often the largest hidden cost.

6. How rePurpose Global Helps You Budget for 2026

Our platform was built specifically for this moment:

✔ SKU → component → sub-component breakdowns for every state

✔ Automatic mapping to Oregon, Colorado, California, MN, MD, ME, and WA

✔ Fee simulation for all 2026 fee schedules

✔ State-level sales allocation support

✔ Harmonized reporting for the May 31, 2026 deadline

One dataset → seven reports → zero duplication.

Frequently Asked Questions 

Why do Oregon and Colorado base 2026 fees on 2024 data?

Both states use the prior-year report to set fees for the following program year. That means 2024 packaging data determines your 2026 payments.

What if I don’t know how many units I sold in each state?

You can use approved estimation models. These can be built from population estimates, for example. rePurpose can help you choose the right formula for your company.

What’s the biggest source of EPR cost variation?

Material choice. Plastics and multilayer formats generally have higher fee categories, while recyclable monomaterials and higher PCR content often reduce costs through eco-modulation.

Do eco-modulation bonuses apply in 2026?

Yes for some states like Oregon and Colorado, but criteria vary by state and will continue to evolve. Brands should model different design scenarios to understand potential advantages.

Should brands expect EPR costs to increase after 2026?

Yes. As more states add programs, recycled-content mandates tighten, and eco-modulation becomes more sophisticated, total compliance costs will rise.

Final Takeaway

2026 is the year EPR becomes real — in budgets, in operations, and in financial planning conversations. Brands that prepare now with harmonized data, clear forecasting, and state-by-state fee simulations will navigate the transition smoothly and avoid cost shocks.