Do you have to report under the new packaging laws?
Seven US states now make brands report, and pay for, the packaging they ship into the state. Check yours in two minutes: exemptions, what to file, deadlines and penalties, with links to the regulators' own pages.
What these laws ask of brands
Under extended producer responsibility (EPR), the company that puts packaging into a state pays for recycling it. In most states that's the brand owner: the company whose name is on the product, even when a co-packer makes it. Producers register with the state's producer responsibility organization (the Circular Action Alliance, or CAA, in six states). Each year they report the pounds of packaging they supplied into the state, by material category, and pay fees based on those pounds.
The report is the hard part. Regulators want weights for every packaging component of every product (bottle, cap, label, box, tape, fill), multiplied by units sold into each state, and mapped to dozens of material categories. They also want a written methodology. Law firm Holland & Knight's review of the first 2026 reporting round said "a single-line methodology is not acceptable" and that producers should "expect stricter scrutiny going forward."
The dates that matter
- California: small producers (under $1M in California sales) had to apply for the exemption by June 1, 2026. There's no late-filing provision, and under CalRecycle's regulations the exemption takes effect only once CalRecycle approves an application.
- January 2027: Oregon and Colorado fee invoices.
- ~June 1, 2027: CAA's annual supply reports for 2026 data. CAA's default date is May 31; the 2027 calendar isn't announced yet.
- Washington: 2027 "early fees" were published on October 1, 2026.
Important
This checker summarizes public rules as of October 3, 2026, from the statutes, regulations, regulator guidance and Circular Action Alliance documents linked in each result. It isn't legal advice, and some points are still unsettled: rulemaking is ongoing and lawsuits are pending in Oregon, Colorado and California. Confirm anything you rely on with the regulator or your counsel.
Guides
- California SB 54 small producer exemption: who qualifies and how to apply
- On Oregon DEQ's producer status list? What it means and what to do
- Oregon EPR lawsuit: where the challenge stands (2026)
- Colorado packaging EPR: is your small business exempt?
- Washington packaging EPR: who's exempt, and the 2027 early fees
- The CAA Annual Supply Report in 2027: what it asks for and when
- Packaging EPR material categories: how to sort your packaging for CAA reports (2026)
- California packaging EPR fees for 2027, by material
- How to weigh your packaging for a CAA report (and what CAA accepts)
- Who reports shipping boxes and fill: the brand, the 3PL, or both?
- Minnesota packaging EPR: do you owe anything, and when?
- Maryland packaging EPR: do you owe anything, and when?
- Maine packaging EPR: do you owe anything, and when?
- Recycled-content registration: Washington and New Jersey
- Compostable product labelling laws by state (CA, CO, WA, MN, MD)
- Selling into Canada: are you exempt from provincial packaging EPR?
All guides