EPR HelpUpdated October 3, 2026

Packaging EPR guides for small brands

Short, specific answers to the questions small brands ask most about the state packaging laws, each with links to the regulators' and the Circular Action Alliance's own documents.

California SB 54 small producer exemption: who qualifies and how to apply
Under $1M in California sales? The exemption isn't automatic. How to file in PEPRS, the June 1, 2026 deadline, and renewal.
On Oregon DEQ's producer status list? What it means and what to do
What the quarterly list is, Oregon's exemption tests, penalties, and how to correct it with DEQ.
Colorado packaging EPR: is your small business exempt?
The inflation-adjusted revenue test, the 1-ton test, 2027 flat dues, and the open question for online-only sellers.
Washington packaging EPR: who's exempt, and the 2027 early fees
The $5M and 1-ton tests, and the per-pound early fees published October 1, 2026.
Minnesota packaging EPR: do you owe anything, and when?
The $2M and 1-ton de minimis tests, CAA membership since July 2025, no fees until around 2029, and the pending MPCA rules.
Maryland packaging EPR: do you owe anything, and when?
The $2M and 1-ton tests, the open question on MDE's exemption form, the June 30, 2027 registration and the 2028 plan dates.
Maine packaging EPR: do you owe anything, and when?
Nothing is due yet: no stewardship organization bid. The $2M and 1-ton tests, the disputed $5M window, and what starts the clock.
The CAA Annual Supply Report in 2027: what it asks for and when
Pounds by category, methodology and attestation, accepted estimation methods, the expected June 1, 2027 date, and the data to collect now.
Who reports shipping boxes and fill: the brand, the 3PL, or both?
State-by-state rules for shipper boxes, mailers and void fill, including 3PLs and Amazon FBA.

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General information, not legal advice. Rules change; we re-verify each season.