Maryland's packaging EPR program took effect May 25, 2026. Our June 22 post gave the wrong effective date and the wrong registration path. This corrects both.

What changed
The June 22 post said producers must register with MDE by July 1 or as an individual producer. That is not how it works for most members. The Circular Action Alliance (CAA), Maryland's designated PRO, files the producer list with MDE. Members register through CAA, not MDE directly. The individual producer (IPP) path exists but is the exception, not the default.

Registration deadline has passed
CAA's member registration and data deadline was May 31, 2026. If you have not registered, contact CAA now to confirm your status and next steps. Start at CAA's Producer Resource Center: https://circularactionalliance.org/producer-resource-center, or contact Producer.Support@circularaction.org.

Being registered with CAA in another state does not satisfy Maryland's requirement. Registration is three separate steps: a CAA company account, Maryland-specific portal registration, and Maryland data submission. All three are required.

Material categories
The reg's registration categories are: Certified Compostable Organics, Paper, Small Format Plastic, Rigid Plastic, Flexible Plastic, Metal, Glass, and Wood and Other Organics. Aerosols and pressurized cylinders are in scope. Steel and aluminum aerosol containers are enumerated under Metal, which affects a large share of auto care products.

Exemptions
The following apply to primary packaging only. Secondary and tertiary packaging associated with an exempt primary package is still covered and must be reported. Several of these require a determination by MDE. Do not assume an exemption applies without confirming through CAA or MDE.

• Small producer: under 1 ton of covered material introduced into Maryland, or under $2 million in global gross revenue
• Hazardous or flammable packaging, where the hazard prevents the packaging from being recycled, reused, or composted
• Long-term packaging (5-plus year use cycle)
• Refillable LPG cylinders
• Primary packaging for products in Maryland's Paint Stewardship Program
• Business-to-business packaging that never reaches a consumer
• Single-retail-location businesses with no online sales that are not part of a franchise or chain

Penalties
Penalties are $5,000, $10,000, and $20,000, escalating. There is no automatic fine. MDE must issue a written notice of violation and provide a 60-day cure period before any penalty applies. Producers who have not registered should still act now. CAA is required to report non-registered producers to MDE quarterly, with contact information and missing data.

Record-keeping
Producers must keep compliance records for 10 years and produce them to MDE within 10 business days of a request, or a longer period if MDE specifies one. If Maryland-specific data is not available, producers may use prorated national data, but only with MDE approval.

What's ahead

• July 1, 2028: Individual producer responsibility plans due if not joining a PRO
• Oct. 29, 2028: sales ban for producers without an approved plan on file, unless MDE sets a later date
• July 1, 2029: annual reporting begins

Questions on your registration status can go to Producer.Support@circularaction.org or to your Auto Care Association state affairs contact