EPR State Guides — Deadlines, Exemptions & Fees

Comprehensive guides covering deadlines, exemptions, penalties, fee structures, and official resources for every state with an active EPR packaging law.

California

SB 54 (2022)

Active — Regulations Finalized, Reporting Due
PROCircular Action Alliance
ExemptionUnder $1M gross sales in California (no volume threshold)
FeesPreliminary 2027 rates
PenaltiesUp to $50,000/day for general entities; up to $25,000/day for small entities per PRC §42081

Next: Final 2027 fee schedule expected by end of October

Oregon

SB 582 (2021)

Active — Fees Due
PROCircular Action Alliance
ExemptionUnder $5M global gross revenue (aggregated across associated producers)
FeesPublished rates
PenaltiesUp to $25,000/day. NAW v. Feldon upheld the RMA in D. Or. (Aug 27, 2026); NAW appealed to the 9th Circuit (filed Sep 24, 2026) — enforcement continues during the appeal. A separate stipulation had paused DEQ pre-enforcement notices for Lollicup USA only through Aug 31, 2026 (case now held in abeyance).

Colorado

HB 22-1355 (2022)

Active — Fees Due
PROCircular Action Alliance
ExemptionUnder $5M realized gross revenue (excl. on-premises alcohol sales; CPI-adjusted annually each Jul 1) OR less than 1 ton of covered materials (C.R.S. 25-17-713)
FeesPublished rates
Penalties$5,000 + $1,500/day (1st offense); $10,000 + $3,000/day (2nd); $20,000 + $6,000/day (3rd+). Non-compliance can restrict selling in CO.

Minnesota

HF 3911 (2024)

Registration Phase
PROCircular Action Alliance
ExemptionUnder $2M global revenue OR less than 1 ton of covered materials (EITHER qualifies for exemption)
PenaltiesUp to $25K/day (1st), $50K/day (2nd), $100K/day (3rd+)

Next: Full needs assessment

Maryland

SB 901 (2025)

Registration Phase
PROCircular Action Alliance (allows multiple PROs)
ExemptionUnder $2M global revenue OR less than 1 ton of covered materials (EITHER qualifies)
Penalties$5K-$20K (PRO); up to $250K for PRO performance failures. Producer penalties after 60-day notice.

Washington

SB 5284 (2025)

Registration Phase
PROCircular Action Alliance
ExemptionUnder $5M global revenue OR less than 1 ton of covered materials (EITHER qualifies)
FeesEarly fees
PenaltiesUp to $1K/day (1st violation), up to $10K/day (2nd+)

Next: Preliminary needs assessment

Maine

LD 1541 (2021)

Pre-Launch — SO Selection
PROStewardship Organization (SO) — TBD (first RFP drew zero bids; DEP revising RFP)
ExemptionUnder $2M global OR <1 ton OR >50% closeout/salvage revenue OR <15 tons perishable food packaging
PenaltiesTBD — not yet included in regulations

Illinois

HB 4064 / SB 1817 (stalled) (0)

Bills Introduced — Stalled Pending Needs Assessment
PROTBD — none enacted yet
ExemptionUnder $2M global revenue OR less than 1 ton into state (EITHER qualifies) — HB 4064 de minimis definition
PenaltiesTBD — bill pending

Next: Statewide Recycling Needs Assessment report due to the legislature (Eunomia study, SWIFR-funded)

New Jersey

S673 / A3744 + S614 (0)

Bills in Committee — No Action Yet
PROTBD — bills in committee
ExemptionUnder $5M gross revenue OR less than 1 metric ton of covered products (S673 small-producer definition)
PenaltiesTBD — bill pending

New York

S 1464 (0)

Bill in Senate Rules — Not Enacted
PROTBD — Bill not enacted
ExemptionUnder $5M global revenue OR less than 2 tons of covered material (EITHER qualifies) — S 1464-A de minimis definition
PenaltiesTBD — bill pending