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)
Not automatic in California — you must file for the exemption with CalRecycle and provide evidence of your in-state sales. Doing nothing leaves you on the state's books as non-compliant.
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< $5.8M 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 gross revenue or < 1 metric ton sold in or into OR
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 DeadlinesPRO membership required since Jul 1, 2026 · Mar 1, 2029: no PRO membership, no sales into WA · Jan 1, 2030 (or 6 months after plan approval): program begins
Required ActionsPRO registration · covered-product reporting · fees
Exemption< 1 ton in-state, or < $5M global revenue, or agricultural employer under RCW 19.30.010
PenaltiesUp to $1,000 per violation/day · Up to $10,000 per violation/day — 2nd and each subsequent
Typical trigger: not a PRO member after Jul 1, 2026. From Mar 1, 2029 a non-member may not introduce covered materials into the state. Penalty only after a certified-mail notice of violation and 60 days to cure.
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 total gross revenue, or < 1 ton of packaging in or into ME, or > 50% of revenue from salvage, closeout, bankruptcy or liquidation goods
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 due Jul 1, 2026 · Jul 1, 2028: Responsibility Plan Due
Required ActionsProducer registration · producer responsibility plan · material 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 producer 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