What do Washington and Maryland require from a packaging producer?
Washington and Maryland both run their packaging EPR programs through CAA, and both are in an early phase of registration and data reporting. In Washington, producers had to be members of a registered producer responsibility organization by July 1, 2026, and the program reaches full operation in 2030. In Maryland, producers registered and sent simplified supply data to CAA by May 31, 2026, and CAA's plan is due to the state on July 1, 2028.
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Washington
Washington's Recycling Reform Act, Senate Bill 5284, covers residential packaging and paper products sold to Washington consumers for noncommercial use. The Department of Ecology oversees it. Producers are the brand owners of the products, and from 2026 they must register with an approved producer responsibility organization and report data on their covered products to it.
CAA is the registered organization that producers join, and a separate organization, Interchange 360, serves the petroleum and lubricants industry. Starting in 2030, the organization is to reimburse service providers for the cost of the residential recycling system.
Maryland
Maryland's law, Senate Bill 901, was signed on May 13, 2025. It covers packaging and paper products sold, offered for sale, imported or distributed in the state, in physical stores and online. The Maryland Department of the Environment oversees it, and the law names CAA as the producer responsibility organization.
The statute also lets a producer assign responsibility by contract to another person, as long as that person has joined a registered producer responsibility organization for the material.
Who is a producer
Both states use a tiered definition that follows the brand owner of the product. For online sales, a law firm summary describes the same twist in both states: the entity that packages the product for shipment is the producer of the shipping materials. The online split is explained in am I a producer: online brands and marketplace sellers.
Dates to know in Washington
- 2026: producers register with a producer responsibility organization and report their data to it
- July 1, 2026: producers had to be members of a registered organization, or registered individually
- September 1, 2026: CAA's one time payment to Ecology is due
- December 31, 2026: Ecology's preliminary needs assessment is due
- October 1, 2028: CAA's draft program plan is due
- 2030: the program is fully implemented and service provider reimbursements begin
Dates to know in Maryland
- May 25, 2026: the state's first implementing regulations took effect
- May 31, 2026: producer registration and the simplified supply report to CAA were due
- July 1, 2026: CAA's registration with the state was due, with a list of participating producers, brands and covered materials by category and weight
- July 1, 2028: CAA's producer responsibility plan is due, and the same date applies to individual producer plans
What this means now
The live obligations in both states are registration and an accurate list of brands and products. Packaging weights and fees come later, but the record that sets them is the same one used in every other state, with a material and weight for each component. It is built once and kept current. The kits guide shows how: kits, sets and bundles in an EPR report.
Primary sources
- Washington Department of Ecology, Recycling Reform Act: the program, the phases and the 2030 reimbursements
- Washington Department of Ecology, Producer Responsibility Organization: who is a producer and what producers must do
- Washington Department of Ecology, Recycling Reform Act will lower recycling costs: CAA and Interchange 360 as the registered organizations
- Maryland Department of the Environment, packaging EPR report to the General Assembly: the statute's producer definitions, including contract assignment
- Holland and Knight, Maryland finalizes first EPR regulations: the May 2026 regulations and the 2026 and 2028 dates
- DLA Piper, Maryland and Washington enact EPR laws: the producer definitions for online sales
- Beveridge and Diamond, Maryland becomes sixth state: scope, exclusions and e-commerce
- Resource Recycling, EPR deadlines approach: the July 1, 2026 dates and the Washington timeline
FAQ
Is a brand paying packaging fees in Washington or Maryland now?
Both programs are in an early phase of registration and reporting. Washington's program reaches full operation in 2030, and Maryland's plan is not due until July 1, 2028.
Does Washington's law cover business to business packaging?
Washington's program covers packaging and paper products sold to consumers for noncommercial use.
Who is the producer for an online order?
The brand owner follows the product. A law firm summary says the entity that packages the product for shipment is the producer of the shipping materials in both states.
How are small producers treated?
Exemptions and thresholds are set out in each state's law and rules. A small brand confirms its status with Ecology, the Maryland Department of the Environment or CAA before assuming it is out.
Who can answer questions?
CAA's Producer Services team is the first contact for reporting guidance in Washington. Ecology's Recycling Reform Act team can be reached at recyclingreform@ecy.wa.gov.
This guide is general information, not legal advice. We work out who the producer is for every product, build the packaging record, prepare and file the report each cycle and keep it current. Check your exposure to see where you stand in Washington, Maryland and the other states, or talk to us.