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Maine EPR Guide

Stewardship Program for Packaging (LD 1541, 2021)

Pre-Launch — SO Selection
PRO
Stewardship Organization (SO) — TBD (first RFP drew zero bids; DEP revising RFP)
Agency
Maine Department of Environmental Protection (DEP)
Exemption
Under $2M global OR <1 ton OR >50% closeout/salvage revenue OR <15 tons perishable food packaging
Fees
No fee schedule proposed. First SO RFP (Jun 15, 2026) drew zero proposals by the Aug 18 deadline; DEP is revising the RFP (announced Sep 11, 2026) — start-up fee timing TBD.
Penalties
TBD — not yet included in regulations

Who is a “producer”?

Under LD 1541, a “producer” is determined in the following order of responsibility:

  1. 1Person with legal ownership of the brand of a product sold in packaging in or into ME
  2. 2Sole entity that imports into ME a product in packaging branded by a person with no US physical presence
  3. 3Person who adds packaging material to another producer's product for direct consumer distribution

What's covered

Covered

  • ✓Packaging material only (NOT printed paper)

Not Covered / Exempt

  • ✕De minimis producers (<$2M global OR <1 ton OR >50% salvage/closeout revenue OR <15 tons perishable food)
  • ✕Long-term storage/protection of durable products (5+ year lifespan)
  • ✕Beverage containers under Maine bottle bill
  • ✕Architectural paint containers (80%+ recycling rate)
  • ✕Packaging used solely for transportation to non-consumers (B2B transport — 38 MRS §2146(1-C), PL 2025 c. 383)
  • ✕Materials excluded by DEP rule

Special Exemptions

Maine has more generous exemption criteria than other states. A producer is exempt if ANY of the following apply:

  • ✓Less than $2,000,000 in global gross annual revenue
  • ✓Less than 1 ton of packaging material into Maine
  • ✓More than 50% of total gross revenue from insurance salvages, closeouts, bankruptcies, liquidations
  • ✓Perishable food producers with less than 15 tons of total packaging material

Key Deadlines

DateWhat's DueStatus
Jun 15, 2026Maine DEP releases first RFP for SO selection (RFP-202605094)PASSED
Aug 18, 2026SO proposal deadline — zero proposals receivedPASSED
Sep 11, 2026DEP announces it will revise and reissue the SO RFPPASSED
Sep 30, 2026Prior DEP estimate for registration/invoicing start (unlikely after RFP restart)PASSED
Oct 1, 2027SO first municipal reimbursements (estimate — contingent on SO contract)FUTURE

Official Resources

Maine Department of Environmental Protection (DEP)maine.gov/dep/waste/recycle/epr.htmlCAA Mainecircularactionalliance.org/circular-action-alliance-maineProducer Resource Centercircularactionalliance.orgRFP-202605094 Announcement: No Proposals Submitted as of Deadlinecontent.govdelivery.comMaine DEP to Revise Request for Proposals for Stewardship Organizationcontent.govdelivery.com38 MRS §2146 Definitionslegislature.maine.gov

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