Summary

Washington’s packaging Extended Producer Responsibility law — the Recycling Reform Act (RCW 70A.208) — requires producers to join a PRO by January 1, 2026, register with the PRO by February 15, 2026, and then be registered by the PRO with the Department of Ecology by March 1, 2026.

Producers must report Calendar Year 2025 packaging data by May 31, 2026, even though full fees and eco-modulation begin later. Washington has uniquely complex producer hierarchies, material exemptions, and a long timeline toward full implementation (Draft Program Plan due 2028; full program launch 2030).

This guide synthesizes statutory language, CAA guidance, and 2026 registration steps so brands can prepare with confidence.

What Is Washington’s Packaging EPR Law?

Washington’s Recycling Reform Act (RCW 70A.208) creates a producer responsibility system for:

• Packaging
  
• Paper products
  
• E-commerce packaging
  
• Shipping packaging
  
• Single-use formats
  

Under this system, producers — defined strictly by statute — must finance, report, and eventually pay eco-modulated fees to improve recycling and recovery systems across the state.

Washington is more complex than Oregon or Colorado because final rules will not be released until 2028, meaning producers must operate in 2026 using statutory definitions only.

Source: CAA Covered Materials & Producer Definitions Guide (Nov 2025) .

Who Must Comply in Washington? (Producer Definitions)

Washington uses one of the most detailed producer hierarchies in any U.S. EPR law.
Per RCW 70A.208.020(29) , a producer is defined differently depending on the sales channel.

1. Packaged Items Sold in Physical Retail

Order of responsibility:

1. Manufacturer, if sold under its brand
   
2. Licensee, if sold under another party’s brand
   
3. Brand owner
   
4. Importer of record
   
5. First distributor into Washington
   

2. Items Sold via E-commerce / Remote Sales

Two producer roles may apply:

• Primary packaging: producer follows the same hierarchy as retail
  
• Shipping packaging: producer is the entity that packages the item for delivery
  

3. Paper Products

Different rules apply depending on product type. Reach out to us for a more in-depth consultation on whether you are liable. 

Which Materials Are Covered in Washington EPR Reporting? (Covered vs Exempt Materials)

Washington defines covered materials broadly as all packaging and paper products introduced into the state.

Covered Materials Include:

• Plastics (rigid + flexible)
  
• Glass
  
• Metal
  
• Paper/fiber
  
• Composite & multilayer packaging
  
• Shipping packaging (e-commerce)
  
• Printed paper (flyers, printed materials, catalogs, brochures)
  

Exempt Materials Include:

• Infant formula packaging
  
• Medical foods
  
• FDA-regulated drugs, medical devices, biologics
  
• Veterinary medical packaging
  
• Hazardous materials under EPA/OSHA
  
• Packaging for products under paint stewardship
  
• Durable packaging (5+ years usage)
  
• Industrial/B2B packaging never reaching consumers
  
• Packaging with extremely high commercial recycling rates (65–70%)
  

Source: RCW 70A.208.020(19) Exempt Materials List .

Which Producers Are Exempt from Washington EPR Reporting?

Per RCW 70A.208.020(29)(b) :

• Government entities
  
• 501(c)(3) or 501(c)(4) nonprofits
  
• De minimis producers: Producers who use less than 1 ton of packaging annually and earn less than $5M in revenue annually.
  
  

2026 Compliance Timeline (Critical Dates)

This integrates both statutory requirements and Circular Action Alliance Washington deadlines.

What You Need to Report in 2026

Washington’s statutory guidance (since rules are not yet published) states producers must prepare to report:

1. SKU-Level Packaging Data

• Packaging components (bottle, lid, film, tray, carton)
  
• Sub-components (labels, adhesives, sleeves, coatings — required in CA and likely relevant here)
  
• Material type (resin code, fiber grade, metal type)
  
• Component weight (grams/kg)
  
• PCR % where applicable
  
• Recyclability profile under WA categories (when released)
  

2. Paper Product Data

For catalogs, flyers, printed materials:

• Publisher/brand/manufacturer hierarchy
  
• Paper grade
  
• Weight
  

3. Washington State Sales Volume

• Exact units sold OR
  
• A compliant estimation model

4. Producer Role & Hierarchy Documentation

• Legal entity
  
• Brand names
  
• Manufacturer vs brand owner vs importer justification
  
  

How to Register and Report (Step-by-Step)

Based on Circular Action Alliance guidance + statutory requirements:

Step 1 — Appoint a PRO (by Jan 1, 2026)

Producers must designate one or more PROs responsible for system design and operations.

Step 2 — Register with the PRO (by Feb 15, 2026)

This unlocks the reporting portal and ensures you are added to the PRO’s master producer list.

Step 3 — PRO Registers You with the Department of Ecology (by Mar 1, 2026)

Failure to register may prevent you from submitting your Annual Supply Report.

Step 4 — Submit 2025 Packaging Data (by May 31, 2026)

Washington uses the same date as CA, OR, CO, MN, MD.

Step 5 — Maintain Active Membership in a PRO (after July 1, 2026)

Producers must either be part of a PRO or operate a separate individual compliance plan.

Fees and Eco-Modulation (What to Expect)

Washington does not charge full EPR fees in 2026.
However:

• The PRO (Circular Action Alliance) must submit a one-time payment to WA Dept. of Ecology by Sept 1, 2026 covering program setup costs.
  
• Producers will fund this indirectly through PRO membership fees.
  
• Full eco-modulated fees begin closer to 2030 after the needs assessments and system design initiatives are completed.

Fee-setting is expected to mirror national CAA methodologies used in Oregon and Colorado

See our 2026 EPR Fees & Budgeting Guide for more details.

Common Pitfalls to Avoid

• Misidentifying the classification of a producer under Washington’s complex hierarchy
  
• Missing component vs sub-component distinctions
  
• Lacking Washington-specific sales allocation
  
• Waiting for 2028 rules instead of preparing 2025 data, which can put you at risk of facing penalties
  
• Assuming shipping packaging is exempt (it is not)
  

How rePurpose Global Supports Washington Compliance

rePurpose Global’s platform is built for the complexity of multi-state EPR:

✔ One packaging dataset mapped to Washington’s statutory categories

Automatically translates your packaging structure into Washington-compliant reporting fields.

✔ Automated producer hierarchy determination

Systematically maps your brand/manufacturer/importer relationships to Washington law.

✔ Washington-state sales allocation modeling

For brands without perfect distribution data.

✔ Audit-ready documentation for 2026–2030

Traceability for every packaging component and data source.

✔ One-click 2026 Annual Supply Report

Export directly into Washington’s reporting format once published.

✔ Future-proof for 2028 rulemaking

The platform will auto-map new categories once Washington releases the Draft Program Plan.

FAQs

What is required for Washington’s 2026 EPR reporting?

Producers must submit Calendar Year 2025 packaging and paper product data by May 31, 2026. This includes material weights, components, paper product categories, and WA sales volumes.

Who is considered the producer under the law?

Washington uses a strict hierarchy prioritizing the manufacturer, then the licensee, brand owner, importer, and first distributor. E-commerce shipping packaging has its own rules.

Are any materials exempt?

Yes. Washington exempts certain medical, hazardous, durable, B2B, and high-recycling-rate materials. The exemption list is more extensive than most U.S. EPR states.

Does Washington charge companies EPR fees in 2026?

No full producer fees expected in 2026 for Washington EPR.

Do I need exact Washington sales data?

Yes — or a documented, defensible estimation methodology.

When does Washington’s full EPR program launch?

Washington’s Draft Program Plan is due in 2028, with full implementation targeted for 2030.

Final Takeaway

Washington’s EPR law is one of the most complex and forward-looking in the United States. With early deadlines in early 2026, mandatory reporting on May 31, and a long runway to 2030 system launch, producers must begin preparing now.

A harmonized data approach — capturing packaging specs once and mapping them across all states — is the only scalable path. rePurpose Global is built for exactly this moment in time in the US regulatory landscape.