WHAT HAPPENED: The Circular Action Alliance (CAA), the designated producer responsibility organization (PRO) for six of the seven states with enacted Extended Producer Responsibility (EPR) packaging laws, has set a supply report deadline of May 31, 2026 — effectively June 1 since May 31 falls on a Sunday — for obligated producers. Chicken processors and other food industry producers that sell packaged products into California, Colorado, Oregon, Maryland, Minnesota, or Washington may be subject to these requirements.
BACKGROUND: EPR laws require companies — including brand owners, manufacturers, and licensees — to register with a PRO, report the weight of “covered materials” (generally single-use packaging, food service ware, and in some states paper products) sold into each state, and pay fees to the PRO.
WHAT’S DUE: Requirements vary by state. Producers in California, Colorado, and Oregon must file annual supply reports covering calendar year 2025 packaging data by material category. Producers in Maryland, Minnesota, and Washington must submit simplified “interim” supply reports for 2025. California producers face additional obligations, including a baseline plastic packaging report for 2023, an annual source reduction report, and — for those seeking a “small producer” exemption (under $1 million in gross California sales) — an exemption application, all due June 1. California producers also have an Individual Source Reduction Plan due August 1, 2026.
WHY IT MATTERS FOR THE CHICKEN INDUSTRY: Chicken companies that sell products in retail or food service packaging in any of these six states should assess whether they qualify as an “obligated producer” under each state’s law. Missing the reporting deadline could expose companies to compliance risk as state EPR programs move from planning into active enforcement phases.
