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Compliance

What Happens If You Miss an EPR Deadline?

April 29, 2026 · 5 min read

If you sell packaged products in the United States, EPR compliance deadlines are not optional. Missing them can cost you tens of thousands of dollars per day — and in some states, it can even restrict your ability to sell products at all.

The penalties by state

California — Up to $50,000/day

Under SB 54, the California Department of Resources Recycling and Recovery (CalRecycle) can impose civil penalties of up to $50,000 per day for each violation. Brands that fail to register, report, or pay fees face escalating penalties.

Colorado — $20,000 + $6,000/day

Colorado's HB 22-1355 allows penalties up to $20,000 for initial violations plus $6,000 per day for ongoing non-compliance. The state can also seek injunctions preventing the sale of non-compliant products.

Minnesota — Up to $100,000/day

Minnesota's HF 3911 includes the steepest penalties: up to $100,000 per day for repeat violations. The state commissioner can also issue compliance orders requiring immediate action.

Oregon — $25,000/day

Oregon's SB 582 authorizes penalties of up to $25,000 per day for violations. The DEQ can also revoke registration for persistent non-compliance.

Beyond fines: the hidden costs

Financial penalties are just the beginning. Non-compliance can also mean:

  • Injunctions — court orders preventing you from selling non-compliant products in that state
  • Reputational damage — public records of non-compliance that customers and partners can find
  • Retroactive fees — you owe fees for all the months you were non-compliant, plus penalties
  • Audit risk — non-filers are more likely to be selected for state audits

What to do right now

  1. Check your obligations — Use our free Am I Covered? tool to see which states require you to register.
  2. Know your deadlines — Check our deadline calendar for each state's registration and reporting dates.
  3. Estimate your fees — Use the EPR fee calculator to budget for compliance costs.
  4. Start the registration process — each state's PRO has an online portal. Don't wait until the deadline.

Not sure where to start?

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