Key Deadlines, Fees, and Reporting Producers Should Prepare For

Key Updates Summary:

2025 was a key year for EPR regulations in the US as multiple states implemented new laws to shift the responsibility of packaging waste to producers.

• 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.
• Washington:
  
  • Washington registration is now live on the CAA portal. Producers must appoint a PRO, such as CAA, by Jan 1, 2026.
• Oregon and Colorado: 
  
  • Late EPR reporting submissions are still being accepted.
• Minnesota:
  
  • The Producer Registration Portal is still open, though the initial deadline has passed.

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.

Notes:

• The regulations will be finalized in 2026. 30 days after the finalization, producers will be expected to submit their final report (2023 data) and take into consideration any changes that the final laws may mandate.
• An individualized source reduction plan will need to be submitted by each producer in 2026 (exact timing TBD). CAA will share guidance on source reduction in the upcoming months based on their overall targets.
• Also in 2026, the producer reporting (2025 data) will be due. Post this, final early fees to set up the California EPR program in 2027 will be due in August 2026.

From 2026 compliance & fees unPacked session:

 So, as producers know in 2025, there has been the reporting deadline for Oregon back on March 31st, 2025, and the Oregon program beginning back on July 1st, 2025. For producers who were obligated in Oregon, they had to report and pay fees in 2025 based on the data that they submitted back in March. So in Colorado, producers who determined obligation in Colorado had to submit a supply report back on July 31st, 2025.

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And this data that they submitted in July helps inform the fees for the 2026 program year. And then lastly, the producers also have the CAA California reporting deadline, which is November 15th, 2025. And that report will help inform the source reduction baseline for California. So unlike 2025 where producers only had to pay fees for Oregon and the Oregon program, which started back in July, in 2026, Oregon's program will continue, Colorado's program will start, and other states like California and potentially Maine will also work on starting their programs.

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So this means in Oregon, producers will pay program fees based on a whole calendar year based on the data that they reported from their 2026 calendar year supply data for that 2026 program year. So if you reported back in March 31st, you didn't have to re-report for this upcoming program year. The invoices for Oregon will be sent in two different installments.

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One will be sent over in January 2026, and then the second will be sent in July 2026. For Colorado, producers will pay program dues — and dues and fees are the same thing — which will be based on their 2024 supply data that they submitted back on July 31st, 2025. And the program dues will cover the 2026 program year and similar to Oregon, invoices will also be sent into installments, which one will be in January, and the other will be in July, 2026.

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So for California, producers will pay early fees that support the pre-program cost. Early fees will be based on reports that producers submit on May 31st, 2026. And producers will pay a one-time fee, so invoices for those early fees will be sent in August, 2026. And then lastly, other fees that producers could expect to prepare for are in states, including May in Maine.

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The reason that Maine is orange on this screen rather than blue like Oregon, Colorado, and California is because CAA has not been selected as the SO or the stewardship organization, which stewardship organization or SO and PROs (producer responsibility organization) are the same, just with a different name.

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So CAA has not been selected as the SO in Maine, but if we are selected, producers can anticipate early fees or startup fees similar to California, which would help support the pre-program costs. Startup fees would be based off of a simplified report that would be due in Q3 of 2026.

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 And the invoices for these early fees would be due in Q4 of 2026. 

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 And then to kind of continue on that same vein, in addition to the different payments that are due in 2026, there are also lots of different reports that are due in 2026 for many of the EPR states. So to support harmonization CAA has aligned the reporting deadlines to mostly be on all May 31st, rather than have them be on different deadlines like they were in 2025.

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So for Oregon, Colorado, and California, producers will need to submit a report based on their supply data from their 2025 calendar. And these reports will inform and cover the 2027 program year, um, in Minnesota and Maryland. They will also have reports that are due on May 31st, but their reports will have a simplified supply report where they would report the aggregated total of materials in eight categories instead of a full material detail report.