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2025 marked a pivotal year for Extended Producer Responsibility (EPR) in the U.S., as multiple states enacted new laws shifting the responsibility for packaging waste to producers. In 2026, that momentum continues. Producers can expect broader implementation across additional states, expanded reporting mandates, major compliance deadlines, and new fees. As EPR regulations evolve, rePurpose is here to help you stay informed, prepared, and compliant with the latest updates and a streamlined EPR compliance solution.

Key Deadlines, Fees, and Reporting Producers Should Prepare For

Key Updates Summary:

• California:
  
  • The Producer Registration Portal is open, and late submissions for California Interim Reporting are still being accepted via the CAA portal. The initial deadline was Nov 15.
  • CAA encourages producers who have not yet reported to start preparing their 2023 baseline supply and component data now and to submit reports as soon as possible. This helps inform CAA's fee setting and source reduction planning.
• Washington:
  
  • Washington registration is live. It remains open on the CAA portal in case producers have not yet registered.
  • Producers must have appointed a PRO, such as CAA, by Jan 1, 2026.
• Oregon and Colorado: 
  
  • Late EPR reporting for 2025 submissions are still being accepted.
  • Invoices are expected to be issued in mid-to-late January 2026. Producers should check their producer portals or emails to authorized contacts for their 2026 invoices.
  • In Oregon, packaging producers may now make a claim for an exemption from paying fees in 2027 for the proportion of their products that are recycled privately through responsible end markets. The claims window is open from Jan. 7 through Mar. 31. Approval or denial of claims will occur by Jun 15.
• Minnesota:
  
  • The Producer Registration Portal remains open, though the initial deadline has passed.
• Maryland:
  
  • Producers will be able to register with CAA beginning in the spring of 2026.

Not sure which EPR states apply to you? Take our free 5-minute assessment to find out. 

What’s Coming in 2026 EPR:

After a year of fragmented timelines and state-by-state nuances, 2026 will be the first year where Extended Producer Responsibility (EPR) obligations in the U.S. begin to harmonize. For producers selling into multiple states, this means clearer expectations, more aligned deadlines, and multiple sets of fees and reports due throughout the year.

Here’s a comprehensive look at what producers can expect in 2026 across Oregon, Colorado, California, and other emerging EPR states.

Harmonized Reporting & Invoicing 

Beginning in 2026, most states — led by Oregon, Colorado, and California — will follow a consistent schedule:

• Annual Supply Reports Due: May 31, 2026
  
  • Annual Supply Report: detailed material data report across all defined categories
• Producer Responsibility Fee Schedules Published: October 2026
• Invoices Issued: January and July (based on the prior year’s data) 2026

This marks a significant shift from 2025, where deadlines varied widely.

Oregon: 

Oregon, the earliest mover, began its EPR program in July 2025. Producers obligated in Oregon already submitted 2025 supply data on March 31, 2025 and paid fees in mid-2025.

In 2026:

• Producers will pay full-year program fees based on their 2024 calendar-year supply data.
• Invoices will be issued twice: January 2026 and July 2026
• No additional reporting is required until the harmonized May 31, 2026 deadline (using 2025 data).
• Non-compliance may result in penalties as high as $25,000/day. 

Compliance doesn’t have to be complex. rePurpose simplifies and streamlines the process with our automated compliance software. One setup and platform fee covers all current and future EPR states with the most up-to-date regulations. 

Colorado: Program Fees Begin in 2026

Colorado required producers to determine obligation and submit 2024 supply data on July 31, 2025. This submission sets the baseline for Colorado’s 2026 program fees.

In 2026, Colorado’s first official program fee year:

• Producers will pay program dues (fees) based on 2024 supply data submitted in July 2025.
• Invoices mirror Oregon’s schedule:
  
  • January 2026
  • July 2026
• Noncompliance penalties include escalating daily fines:
  
  • The first violation is $5,000 for the first day and $1,500 for each following day. 
  • The second violation is a $10,000 initial penalty and $3,000 per subsequent day. 
  • The third violation incurs an initial $20,000 fine and $6,000 for each following day.

In addition to fines, non-compliance can lead to the restriction of selling products in the state.

California: Early Fees and Major Regulatory Finalization

California’s EPR program (SB 54) remains the most complex and 2026 is the year it formally ramps up.

Early Fees in 2026

Producers will:

• Submit material data supply reports by May 31, 2026 (for 2025 data)
• Pay one-time early-fees based on invoices issued in August 2026. These early fees fund California’s pre-program activities ahead of the full 2027 program launch.

Final Regulations and Additional Reporting

California’s regulations will be finalized during 2026. Producers will be required to:

• Submit a final 2023 data report within 30 days of regulation finalization. This allows the state to integrate any last-minute compliance-mandated changes.

Additionally:

• Producers will submit a producer supply report using 2025 data by May 31, 2026.
• Producers must develop and submit an individualized source reduction plan (timing TBD), guided by state-defined reduction targets. CAA will publish guidance in the months leading up to this requirement.

Together, these steps set the foundation for California's formal program activation in 2027.

If these evolving regulations feel overwhelming, our team is here to help. Book a call with us to see how rePurpose simplifies this reporting process.

Maine and Other States: Potential Startup Fees in 2026

Maine’s EPR program continues developing, but unlike the other states, CAA has not yet been selected as the stewardship organization (SO/PRO). If selected:

• Producers can expect startup fees similar to California’s early-fee model.
• A simplified supply report would be due in Q3 2026.
  
  • Simplified supply report: higher level report with fewer categories at the material class level (e.g. plastic, paper, glass) 
• Invoices for startup fees would likely be issued in Q4 2026.

Maryland and Minnesota will also require simplified reporting in 2026, although neither state requires a full detailed material breakdown yet.

Summary: What Producers Must Prepare For in 2026

Multiple fees across multiple states
— Oregon: two invoices (Jan & July)
— Colorado: two invoices (Jan & July)
— California: one early-fee invoice (Aug)
— Potentially Maine: startup-fee invoice (Q4)

Three different types of reporting
— 2025 supply reports (May 31)
— California final 2023 report (30 days after final regs)
— California individual producer plastic source reduction plan using 2023 baseline data (TBD)

Looking Ahead

2026 will be the most operationally intensive year for producers navigating EPR. With multiple reports, fee cycles, and regulatory updates converging, producers who prepare early and centralize their compliance processes will be positioned for a much smoother transition into 2027.

A Smarter Way to Manage 2026 EPR: rePurpose 

The rePurpose packaging compliance platform centralizes supply data, harmonizes reporting formats across states, and keeps producers ahead of every deadline, from May 31st submissions to August early fees and January/July invoices.

Whether you're managing reporting for one state or all six emerging EPR programs, rePurpose helps ensure accuracy, reduce manual effort, and streamline compliance as regulations rapidly evolve. Book a demo with our team.

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