EPR Deadline 2026 — File by May 31 or Pay
May 2026 · 6 min read
May 31, 2026 is the harmonized EPR reporting deadline for brands selling packaged products in California, Oregon, Colorado, Minnesota, Maryland, and Washington. If you're a brand owner, licensee, or importer, this affects you. Here's exactly what you need to know — and what happens if you miss it.
What is the May 31 EPR reporting deadline?
May 31, 2026 is the first harmonized reporting deadline under six state EPR packaging laws. On this date, brands that sell packaged products into these six states must submit their annual packaging reports to their respective Producer Responsibility Organizations (PROs).
This is not a future deadline — it's happening now. The laws are already in effect. The reporting window is open. And penalties for non-compliance start immediately after the deadline passes.
Not sure if you're covered? Check in 60 seconds with our free coverage checker.
State-by-state: What's due May 31
California (SB 54) — Up to $50,000/day
California's SB 54 requires all "producers" (brand owners, licensees, importers) selling packaged products into the state to report packaging weight data to the CalRecycle-approved Producer Responsibility Organization. Brands with over $1M in CA sales are subject.
Filing: Annual packaging weight report by weight and material type
Full California guide →Oregon (SB 582) — Up to $25,000/day
Oregon's SB 582 requires producers to register with a PRO and submit packaging weight data. Brands with over $5M global revenue are subject. The state is currently in the registration and initial reporting phase.
Filing: PRO registration + annual packaging report
Full Oregon guide →Colorado (HB 22-1355) — $20,000 + $6,000/day
Colorado's HB 22-1355 covers all producers of packaged products sold in the state. Registration is open and annual reporting is required. Fines escalate with each offense.
Filing: PRO registration + annual packaging report by material type
Full Colorado guide →Minnesota (HF 3911) — Up to $100,000/day
Minnesota's EPR law covers producers with over $1M global revenue who introduce more than 1 ton of packaging into the state. Reporting is through the state-designated PRO.
Filing: PRO registration + annual packaging report
Full Minnesota guide →Maryland (SB 901) — $5K–$20K for PRO violations
Maryland's EPR law is in the registration phase. Producers meeting the threshold must register with the PRO and prepare for initial reporting obligations.
Filing: PRO registration + initial reporting
Full Maryland guide →Washington (SB 5284) — Up to $10K/day
Washington's EPR law is in the registration phase. Producers meeting revenue or volume thresholds must register. Full fee reporting begins in 2027.
Filing: PRO registration + initial reporting
Full Washington guide →What you need to file
Regardless of which state you're reporting to, you'll need these three things:
- PRO registration— You must be registered with the designated Producer Responsibility Organization for each state where you're obligated. Registration is separate from reporting.
- Packaging weight data by material type — Total weight (in kg or lbs) of packaging sold into each state, broken down by material: recyclable plastic, non-recyclable plastic, corrugated cardboard, paperboard, glass, aluminum, and steel.
- Eco-modulation data (if applicable)— Documentation of any eco-modulation credits you're claiming: mono-material packaging, PCR content percentage, consumer recycling labels, source reduction.
Not sure how much your packaging weighs? Estimate your fees with our calculator— it'll give you a weight-based cost estimate by state.
What happens if you miss the deadline
Penalties are not theoretical. They are written into law and enforced by state agencies. Here's what's at stake:
- California: Up to $50,000 per day of non-compliance
- Minnesota: Up to $100,000 per day for repeat violations
- Colorado: $20,000 + $6,000/day for ongoing violations (3rd offense)
- Oregon: Up to $25,000 per day
- Washington: Up to $10,000 per day (2nd+ violations)
Beyond fines, non-compliance can restrict your ability to sell products in those states. Read the full penalty breakdown →
What to do right now
- Check your obligations — Use our free Am I Covered? tool to see which states require you to register.
- Know your deadlines — Check our deadline calendar for each state's registration and reporting dates.
- Estimate your fees — Use the EPR fee calculator to budget for compliance costs.
- Gather packaging weight data — Compile total packaging weight by material type for each state you sell into.
- Review eco-modulation opportunities — Check if you qualify for fee credits — see 7 strategies to reduce your fees.
- Start the registration process— each state's PRO has an online portal. Don't wait until the deadline.
What comes after May 31
May 31 is just the beginning. After the reporting deadline:
- August 2026: California begins issuing early fee invoices based on reported data
- January 2027: Oregon and Colorado program fees take effect
- July 2027: Additional state fee periods begin
- January 2028: California full program fees begin
Staying ahead of these dates matters. View the full deadline calendar →
Not sure where to start?
Our free tools help you check your obligations and estimate your fees in 60 seconds.