2027 EPR Fee Schedules Are Out — and the Differences Between States Are Significant

On October 1, Circular Action Alliance (CAA) published updated 2027 packaging EPR fee schedules for California, Colorado, and Oregon — along with an early-fee schedule for Washington. If you sell packaged products in more than one of these states, the numbers highlight a growing challenge: the same packaging material can carry dramatically different compliance costs depending on where it's sold.

Here's what stands out in each state, and what producers should do about it.

Oregon: fees declining

Oregon is the outlier — fees are going down. Median material fees decrease approximately 48%, as roughly $80 million in accumulated reserves is returned to producers through fee reductions. Two headline rates: aluminum cans drop to −$0.09/lb (yes, a negative rate) and glass reaches $0.

Not everything gets cheaper. Certain materials, including molded-pulp food serviceware, remain comparatively expensive — so a material swap that looks like an easy win deserves a per-material check before you commit.

Colorado: fees increasing

Colorado moves the other direction: fees rise on 44 of 61 material categories, with a median increase of approximately 14%. The steepest signal is expanded polystyrene (EPS), now around $2.09/lb — among the highest rates across the three states.

The lesson from Colorado isn't just the increase — it's that recyclability and material selection continue to have significant cost implications. Two producers with the same tonnage can see very different 2027 bills depending on which side of the eco-modulation curve their materials sit on.

California: plastic fees take center stage

California's preliminary 2027 rates under SB 54 introduce substantial plastic-related costs. A plastic pollution mitigation charge adds approximately $0.29/lb plus $0.001 per component, and clear PET packaging is projected at approximately $0.41/lb. For component-heavy formats — closures, pumps, dispensers, labels — that per-component charge adds up quickly.

One caveat: these rates remain provisional pending CalRecycle approval of the program plan. Plan with ranges, not finals.

Washington: early fees introduced

Washington published its first fee schedule: initial 2027 early-fee rates range from $0.002 to $0.030/lb across eight material-based fee categories. The rates are low compared to the other three states — early fees are a bridge to full program launch, not the end state — but they confirm that Washington is moving.

If Washington hasn't been part of your multistate compliance planning yet, it's time to add it.

The four states at a glance

What does this mean for producers?

EPR compliance is becoming more than a reporting obligation. It's increasingly a packaging cost-management issue.

A packaging decision that makes financial sense in Oregon may carry substantially higher fees in Colorado or California. Oregon's negative aluminum rate and Colorado's $2.09/lb EPS rate aren't just line items — they're incentives pointing in opposite directions for the same material decisions.

Three steps to take now

1. Recalculate 2027 EPR exposureusing the updated state-specific fee schedules — not last year's rates. Estimate your fees by state.
2. Review packaging specifications at the component level— material composition, weight, recyclability, and recycled content. California's per-component charge makes component-level data a direct cost lever.
3. Evaluate packaging alternatives on their combined environmental and financial impact across multiple states. 7 ways eco-modulation cuts EPR fees.

The bigger takeaway

Accurate packaging data is no longer just about compliance. It's becoming essential to controlling costs and making informed packaging decisions. As EPR programs expand, producers and suppliers need standardized, reliable material data that can support multiple state requirements without rebuilding their reporting processes each year.

For a full per-material rate comparison, see EPR packaging fee rates by state, or check which states cover you.

Source: Circular Action Alliance — 2027 Fee Schedules (published October 1, 2026). Read the schedules yourself: Oregon fee schedule (PDF), Colorado dues schedule (PDF), California fee schedule (PDF), Washington early fee schedule (PDF), or on circularactionalliance.org (CA · CO · OR · WA producer-fee pages). California rates provisional pending CalRecycle approval of the program plan.