The U.S. packaging landscape is currently dominated by a single, critical date: May 31, 2026. This marks the first major synchronized reporting window across multiple states. For producers (defined generally as brand owners, manufacturers, or importers), failure to submit verified data by this deadline constitutes a violation of state law, with enforcement mechanisms already active in several jurisdictions.
TABLE OF CONTENTS
The Multi-State Reporting Window: May 31, 2026
The Circular Action Alliance (CAA), acting as the approved Producer Responsibility Organization (PRO), has established May 31 as the deadline for reporting 2025 supply data. This requirement applies to six states, though the granularity of the data required varies significantly by jurisdiction.
- California, Colorado and Oregon: These states require Full 2025 Supply Data Reporting. Producers must provide a component-by-component breakdown of all packaging materials (weight, resin type and recyclability status).
- Minnesota, Maryland and Washington: Producers in these states must submit Simplified 2025 Supply Data. This serves as an initial data set to inform future fee structures and state-wide “needs assessments.”
- Maryland Update: Producer registration for Maryland officially opened on March 31, 2026. Producers must execute the state-specific addendum and complete registration prior to the May 31 submission.
California (SB 54) – Triple Reporting Requirements
California remains the most complex jurisdiction due to its additional mandates for plastic reduction. By the May 31, 2026 deadline, producers must submit three distinct sets of data:
- 2025 Producer Supply Report: Standard annual data on all packaging materials.
- 2023 Baseline Producer Report: A final, verified account of 2023 packaging volumes to serve as the benchmark for future reduction targets.
- Annual Source Reduction Report: Documentation of plastic components and weight for the 2025 calendar year.
Furthermore, CAA has confirmed that the Individual Source Reduction Plan (ISRP) must be submitted no later than August 1, 2026. This plan must detail exactly how the producer will achieve the mandated 25% reduction in plastic packaging by 2032.
Oregon – Enforcement Status and Legal Standing
As of April 2026, the status of Oregon’s Plastic Pollution and Recycling Modernization Act (RMA) is subject to a specific court order. On February 6, 2026, a preliminary injunction was issued, but it is not a general pause for all companies.
- Limited Scope: The injunction applies only to members of the National Association of Wholesaler-Distributors (NAW) who were active members as of February 6.
- Active Enforcement: For all other producers, the Oregon Department of Environmental Quality (DEQ) is actively enforcing compliance. On April 10, 2026, the DEQ published a non-compliance list of companies that failed to respond to initial notices.
- Penalty Risk: Non-compliance in Oregon carries civil penalties of up to $25,000 per day, per violation.
Colorado – Transition to Fee Payments
Colorado has progressed beyond data collection and into active financial obligations.
- January 2026: Producers began paying their first round of responsibility dues based on previous supply reports.
- June 9, 2026: CAA is scheduled to begin full-scale implementation of the approved Program Plan. Producers who have not submitted their 2025 data by the May 31 deadline will face immediate adjustments to their fee tiers and potential administrative penalties.
Summary Checklist for May 2026
To maintain compliance, producers must complete the following technical actions before May 31:
- Register for New States: Complete the registration and sign addenda for Maryland, Minnesota and Washington.
- Data Verification: Audit 2025 material datasets for “plastic component counts” which are specifically required for California’s reports (weight alone is insufficient).
- Contract Review: Confirm that supplier agreements provide for the “right to audit” packaging data, as producers are legally liable for the accuracy of the weights reported to the PRO.
Conclusion
The window for technical adjustment is closing. With May 31, 2026, serving as a unified deadline for six states, the primary risk is no longer the fees themselves, but the data gap. Regulatory agencies, particularly in California and Oregon, have demonstrated that they will use daily fines to compel reporting. Producers must ensure that their 2025 material footprint is finalized and uploaded to the CAA portal as soon as possible to avoid being named on state non-compliance lists.
Sources
- Circular Action Alliance (n.d.) EPR for Paper and Packaging – Producer Reporting. Available at: https://circularactionalliance.org/producer-reporting
- Circular Action Alliance (n.d.) California – Extended Producer Responsibility. Available at: https://circularactionalliance.org/california
- Oregon Department of Environmental Quality (n.d.) Producers of Covered Products. Available at: https://www.oregon.gov/deq/recycling/pages/producers-of-covered-products.aspx
- Colorado Department of Public Health and Environment (n.d.) Producer Responsibility Program. Available at: https://cdphe.colorado.gov/hm/epr-program
