May EPR Update: Key Changes and Impacts for Businesses
- Frank Colombo
- 2 days ago
- 3 min read
Above is the latest map of states who have implemented, or have introduced EPR Laws. We will update this map quarterly.
In the months of April and May 2026, there have been several key updates across the 7 states that have implemented EPR laws as well as changes to some states who have introduced legislation to implement EPR:
Oregon Ramps Up Enforcement With First Non-compliance List
The Oregon DEQ published its inaugural quarterly Producer Status List, flagging roughly 250 producers (including brands like Yamaha, Mercedes-Benz, Papa John’s, and Hobby Lobby) for failing to register, report, or pay fees under the Recycling Modernization Act. This marked the first active enforcement wave in the nation’s first operating packaging EPR program.
New York Introduces Nearly 150 Amendments to PRRIA
Senator Pete Harckham and Assemblymember Deborah Glick announced sweeping revisions (~150 changes) to the Packaging Reduction and Recycling Infrastructure Act. The updates align the bill more closely with other states (e.g., updated “producer” definitions and timelines) following stakeholder input. The bill remains in committee.
California Finalizes SB 54 Permanent EPR Regulations
The Office of Administrative Law approved and filed CalRecycle’s permanent regulations for SB 54. They took effect immediately, triggering producer obligations for registration (by June 1), baseline/annual supply reports (May 31), source reduction plans, and eventual fees. This is after a complete restart of SB54 that was ordered by Gov. Newsome in 2025.
CAA And States Confirm Harmonized May 31, 2026 Reporting Across Six States With California’s rules final, CAA and agencies reinforced the unified deadline for 2025 data submissions (full or simplified reports) in CA, CO, OR, MD, MN, and WA — widely called the first major synchronized “Mega May” compliance event.
Maine EPR Implementation Lags With No Stewardship Organization (SO) Selected
Despite the planned May 2026 window for producers to register and submit simplified 2025 packaging tonnage estimates, the Maine DEP has not yet released the RFP for the Stewardship Organization (responsible for operations and fee collection). DEP stated it anticipates releasing the RFP “soon,” with full program operation (including municipal reimbursements) now targeted for 2027. No fees are being collected yet.
https://www.packagingdive.com/news/maine-extended-producer-responsibility-packaging-timeline/819335/
Looking Ahead: The Path to Real Impact
As you can see from the headlines and linked developments, six of the seven EPR states (California, Colorado, Maryland, Minnesota, Oregon, and Washington) are actively harmonizing reporting deadlines through the Circular Action Alliance (CAA). The May 31, 2026 deadline represents a significant step forward.
We hope this coordination continues — ideally moving toward a single standardized reporting form and, someday, one centralized upload portal that feeds all state stewardship organizations (six for now, until Maine selects its Stewardship Organization). Further harmonization of key definitions — what counts as “recyclable,” “compostable,” and consistent material classifications — would dramatically reduce complexity for producers while improving program effectiveness.
It’s encouraging to see states like Oregon publicly naming non-compliant companies. For these laws to deliver meaningful environmental results, full participation is essential. Transparency around fee usage is equally important: each state should clearly communicate how collected funds are allocated.
In my opinion, the highest and best use of these funds is strengthening collection systems at the household level. The blue bin (curbside) system remains by far the most widely used recycling collection method for single-family homes across the United States. While multifamily recycling participation has declined in recent years, it also offers the greatest potential for raw tonnage growth.
The core challenge with today’s blue bin programs is the widespread shift to single-stream collection. This convenience for residents places heavy demands on Materials Recovery Facilities (MRFs), which must perform highly sophisticated sorting. Traditional MRFs were designed primarily for corrugated cardboard, paper, aluminum, plastic bottles, and glass. They are generally not equipped to handle plastic bags, pouches, or to efficiently separate plastics by resin type.
EPR fees would deliver the greatest impact by funding targeted upgrades to MRFs across these states — improving sorting technology, reducing contamination, and increasing the percentage of collected material that actually gets recycled instead of being landfilled.
If you would like more information on EPR laws or your company is required to comply and you need help getting started, please reach out.