CoverageProducers supplying covered single-use packaging or plastic single-use food service ware in CA
PROCircular Action Alliance (CAA)
Key DeadlinesAug 3, 2026: ISR Plan · By Jan 1, 2027: Program Begins
Required ActionsCAA registration · annual reporting · PRO fees by material type
Exemption< $1M in-state revenue (no tonnage threshold)
PenaltiesUp to $50,000/day per violation · Corrective Action Plan · Selling ban
Typical trigger: selling packaged goods in CA without CAA registration or PRO membership
CoverageProducers of covered packaging materials and paper products sold in CO
PROCircular Action Alliance (CAA)
Key DeadlinesProgram active · Register and report immediately if missed
Required ActionsCAA registration · annual packaging data reporting · PRO fees · record-keeping audits
Exemption< $5.5M global revenue or < 1 ton in-state
Penalties1st: $5,000 + $1,500/day · 2nd: $10,000 + $3,000/day · 3rd+: $20,000 + $6,000/day · Selling ban
Typical trigger: shipping covered plastic packaging into CO without CAA registration
CoverageProducers of covered products sold in OR
PRO / AgencyCircular Action Alliance (CAA) · Oregon DEQ
Key Deadlines2026 fees active · Payment dates per CAA invoice
Required ActionsCAA registration · annual packaging data · PRO fees · records on request
Exemption< $5M global revenue or < 1 ton in-state
PenaltiesUp to $25,000/day (DEQ) · Non-compliant member list · Selling ban
Typical trigger: selling covered products in OR without CAA membership or missing annual report
NoteEnforcement paused as of Feb 6, 2026 for NAW members
PROCircular Action Alliance (CAA)
Key DeadlinesRegistration passed — act now · Jan 1, 2030: Program Begins
Required ActionsCAA registration · packaging data reporting · eco-modulated fees by 2030
Exemption< $5M global revenue and < 1 ton in-state (both required)
PenaltiesUp to $1,000/day · Up to $10,000/day for repeat offenses
Typical trigger: selling into WA after Jul 1, 2026 without CAA registration
NoteAnnual reporting and fee deadlines TBD
PROMaine Stewardship Organization (SO)
Key DeadlinesSO selection pending · Registration and invoicing anticipated late 2026
Required ActionsJoin SO · pay SO fees · reimburse municipalities for end-of-life costs
Exemption< $2M global revenue or < 1 ton in-state
PenaltiesSelling ban · No fines currently · Future civil fines possible
Typical trigger: selling packaged products in ME without joining the state Stewardship Organization
PROCircular Action Alliance (CAA)
Key DeadlinesPRO membership required · Jan 1, 2029: Approved-plan participation required
Required ActionsCAA registration · packaging data reporting · cover 50% of costs by Feb 2029, 90% by 2031
Exemption< $2M global revenue or < 1 ton in-state
Penalties1st: up to $25,000/day · 2nd: up to $50,000/day · 3rd: up to $100,000/day
Typical trigger: missing CAA registration after Jul 1, 2025 deadline
PROCircular Action Alliance (CAA)
Key DeadlinesRegistration requirements active · Jul 1, 2029: Annual Reporting Begins
Required ActionsCAA registration · annual material type & supply metrics reporting
Exemption< $2M global revenue or < 1 ton in-state
Penalties1st: $5,000 · 2nd: $10,000 · 3rd: $20,000
Typical trigger: selling packaged goods in MD without CAA registration after Jul 1, 2026
NoteFees not yet scheduled; expected prior to Jul 1, 2028
StatusLegislation under review — 2026/2027 expected
Action Required NowMonitor for passage; prepare data infrastructure
StatusLegislation under consideration
Action Required NowMonitor for updates
StatusNo active EPR law — assessment recommended
Action Required NowAssess data readiness for future legislation
StatusNo active EPR law — legislation activity expected
Action Required NowMonitor for updates
StatusNo active EPR law — legislation activity expected
Action Required NowMonitor for updates
StatusHB750 (2025) enacted — statewide EPR needs assessment due Dec 2027. Broader bill HB1264 under consideration in 2026.
Action Required NowMonitor for updates
StatusEPR Commission established (2024); final report issued Jan 2026 — a typical precursor to legislation.
Action Required NowMonitor for legislation; begin data readiness assessment
StatusStudy bill enacted — statewide recycling assessment due Dec 2026. Full EPR legislation expected to follow.
Action Required NowMonitor for updates