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Maryland

Packaging and Paper Products – Producer Responsibility Plans Act (SB 901, 2025)

Registration Phase
PRO
Circular Action Alliance (allows multiple PROs)
Agency
Maryland Department of the Environment (MDE)
Exemption
Under $2M global revenue OR less than 1 ton of covered materials (EITHER qualifies)
Fees
Fees begin 2028-2029. PRO five-year plan due Jul 2028.
Penalties
$5K-$20K (PRO); up to $250K for PRO performance failures. Producer penalties after 60-day notice.

Who is a “producer”?

Under SB 901, a “producer” is determined in the following order of responsibility:

  1. 1Manufacturer (if sold under manufacturer's brand or no brand)
  2. 2Licensee (if licensed to manufacture/sell under another's brand)
  3. 3Brand owner
  4. 4Importer of record into the US for sale in MD
  5. 5Person who first distributes the item in or into MD

B2B packaging is explicitly exempt in Maryland.

What's covered

Covered

  • ✓Packaging (all types)
  • ✓Paper products
  • ✓Beverage containers (<5 liters, all materials)
  • ✓Online/e-commerce sales

Not Covered / Exempt

  • ✕De minimis producers (<$2M global OR <1 ton into state)
  • ✕B2B packaging (distributed to commercial entity for production)
  • ✕Infant formula, medical food, fortified nutritional supplements
  • ✕Drugs/medical devices (FDA regulated)
  • ✕EPA-regulated pesticides/FIFRA products
  • ✕LPG containers designed to be refilled
  • + 5 more exemptions

Key Deadlines

DateWhat's DueStatus
Jul 1, 2026PRO must register annually with MDEUPCOMING
Jul 1, 2028PRO submits first five-year planFUTURE
Jul 1, 2028Each producer submits producer responsibility plan to MDEFUTURE
Jul 1, 2029Data reporting beginsFUTURE
Jul 1, 2028Reimbursements begin (50% of cost/ton)FUTURE
Jul 1, 2029Reimbursements increase (75% of cost/ton)FUTURE
Jul 1, 2030Reimbursements increase (90% of cost/ton)FUTURE

Official Resources

Maryland Department of the Environment (MDE)mde.maryland.govCAA Maryland Portalcircularactionalliance.org/circular-action-alliance-maryland

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