Key extended producer responsibility (EPR) deadlines are approaching in Washington. The state’s EPR law, the Recycling Reform Act, requires producers to appoint a Producer Responsibility Organization (PRO) by January 1, 2026; and requires the PRO to register with the Washington Department of Ecology on behalf of its producers by March 1, 2026. Circular Action Alliance (CAA) has requested producers in Washington to register with CAA by December 15, 2025, to appoint it as their PRO. More information on registration can be found on CAA’s website, here. To help companies determine their EPR obligations, CAA has released guidance on covered producers and materials in Washington, available here.
With respect to EPR updates in other states, CAA expects Maryland to release the first of two EPR rulemaking packages by late 2025. This first package will focus on the covered materials list and exemptions. The Maryland Department of the Environment (MDE) plans to begin work on the second package in summer 2026. Additionally, CAA will issue 2026 EPR fee invoices for Oregon and Colorado in January 2026.
