Maryland and Washington Join Growing List of States with Packaging EPR Laws

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Greenberg Glusker LLP

[co-author: Bryce Lourié]

Maryland and Washington have joined the growing list of states enacting extended producer responsibility (EPR) laws for packaging and paper products. These laws shift the cost of recycling these materials from the consumer back to the producer and are intended to reduce waste and promote recycling.

Maryland

On May 13, Maryland Governor Wes Moore signed Senate Bill 901, an EPR law that covers packaging (including bottles) and paper products. Under this law, producers must join a Producer Responsibility Organization (PRO) by July 1, 2026, and begin assuming the costs of local recycling programs by July 2028.

Washington

On May 17, Washington Governor Bob Ferguson signed Senate Bill 5284, the Recycling Reform Act, which covers packaging and paper products. Under this law, producers must join a PRO by July 1, 2026.

Circular Action Alliance (CAA), the PRO for other states with existing EPR laws, will likely serve as the PRO for Maryland and Washington as well.

Upcoming Deadlines for Other States

Minnesota: The registration deadline with CAA for obligated producers selling paper and packaging products in Minnesota is July 1, 2025.

Colorado: Obligated producers selling paper and packaging products in Colorado must submit their first report to CAA by July 31, 2025. While this is a preliminary deadline set by CAA, submitting by this date may help ensure the most accurate fees for producers.

For more information on EPR laws around the country, see our previous article, Moving Targets: Multi-State EPR Packaging Laws—Key Updates and Deadlines.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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