The Latest in Maryland EPR

Maryland’s EPR regulations officially went into effect under COMAR 26.04.14 Packaging and Paper Products — Producer Responsibility as of May 25, 2026. This means that producers are now financially responsible for the collection and processing of their product packaging. 

If you’re wondering about this timeline, given Maryland’s May 31, 2026 reporting deadline, you’re not alone in the confusion. Maryland’s SB 901, the legislation that created the state’s EPR program, was passed and signed into law in May 2025. Since then, the Maryland Department of the Environment (MDE) drafted regulation specifics, built the framework, and hosted public comment periods before finally launching the program into full effect on May 25th, 2026.

Does This Change the Maryland EPR Deadline?

No. Registration remains open in the CAA portal, and the first Simplified Supply Report is due May 31, 2026 (adjusted to June 1, 2026) with 2025 supply data. If you haven’t gotten started, it’s not too late. Get started now to avoid penalty fees for non-compliance.

Maryland Is In Pre-Program Status. When Does The Full Program Begin?

Maryland is still in its pre-program phase, and the simplified reporting at the material class level will help CAA develop a program plan. The official program plan is expected to begin in 2029 with detailed annual reporting. Here are the key program dates you need to know for Maryland EPR:

• May 31, 2026 (June 1, 2025): The first Simplified Supply Report is due.
• July 1, 2026: Producers must register with the Maryland Department of the Environment (MDE) through CAA or as an individual producer (reporting without a PRO). 
• July 1, 2027: On or before this date, the MDE will publish a statewide list of covered materials determined to be recyclable or compostable through curbside recycling programs. 
• July 1, 2028: 
  
  • This marks a full program milestone. Producers must submit a comprehensive 5-year Producer Responsibility Plan to the Department for review and approval (through CAA or individually).
    The plan should explain how they will manage, fund, and improve the recovery of covered materials. The plan can also propose an alternative management plan. Plans must be updated and resubmitted every 5 years thereafter.
  • Producers will also be required to begin covering recycling costs included in their registration fees.
• October 29, 2028: Producers will be restricted by a sales ban, disallowing them to sell, distribute, or import covered packaging materials if they do not have an approved Producer Responsibility Plan on file with the MDE.
• July 1, 2029: Detailed annual reporting begins. This reports on the progress toward meeting plan requirements and goals for the prior calendar year. 

Maryland's program plan is an early signal of how much more is coming. As deadlines near and penalties like non-compliance sales bans become real, producers who stay proactive will be far better positioned than those who wait. rePurpose stays ahead of these regulations for you and with you. Connect with our team to see how we help you streamline annual reporting and comply with EPR requirements for Maryland, along with all other active and incoming EPR states.

Who Are The Obligated Producers?

In alignment with other state EPR laws, producers are defined as a company that:

• Manufactures and sells packaged products in Maryland under its own brand
• Imports packaged products into Maryland for sale
• Licenses a brand to another company that sells products in Maryland
• Sells products through its own retail storefront (including e-commerce) and ships directly to Maryland consumers

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Is There A Small-Producer Exemption?

Yes, small producers are exempt if they:

• Introduced less than 1 ton of covered material into Maryland
• Or earned global gross revenues of less than $2,000,000.

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See more specifications about producer and material exemptions here. 

What Are The Covered Materials In The Simplified Supply Report?

The 8 categories in the Simplified Supply Report include:

• Printing and Writing Paper
• Glass and Ceramics
• Metal
• Paper/Fiber
• Rigid Plastic
• Flexible Plastic
• Wood and Other Organic Materials
• Compostable Materials

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These can be found in the CAA-provided Maryland Simplified Supply Report Workbook.

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What Happens If a Company Doesn't Comply?

Missing the registration deadline isn't a free pass. Companies that fail to register on time can face financial penalties and may be required to back-pay registration fees. And the PRO system adds another layer of accountability. If a PRO knows a producer is out of compliance, it's obligated to report them, which can lead to reputational damage and de-shelving.

Reporting and Record-Keeping

Beyond that, companies don't just have to comply. They have to be able to prove their packaging recyclability progress. Records must be kept for at least five years and handed over to the state within 15 business days if requested. Producers need to report data on recycling rates, collection rates, and how much recycled content is in their packaging.

If a company doesn't have Maryland-specific data, they can use prorated national figures as a stand-in, but only with state approval.

The Impact On Maryland Recycling Services 

Behind the complexity of these regulations is a straightforward goal. This regulation funds a new set of covered services beyond the traditional curbside recycling. It also supports a wider range of collection and processing systems that companies can use to meet their obligations, including drop-off and depot collection programs, take-back programs, reuse and refill services, mail-back and specialty collection programs, and private subscription-based collection programs. 

Bottom Line

If you sell packaged goods in Maryland, you need to register as a producer and submit your Simplified Supply Report today. Get started, and get ahead. 

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The rePurpose packaging compliance platform centralizes supply data, harmonizes reporting formats across states, and keeps producers ahead of every deadline. Book a demo with our team.

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