Maryland Packaging EPR Takes Effect June 30 Registration Deadline July 1

What's New

Maryland's packaging Extended Producer Responsibility (EPR) regulations were finalized on May 15, 2026 and take effect June 30, 2026 under COMAR 26.04.14. The program stems from the Packaging and Paper Products -- Producer Responsibility Plans Act (SB 901), signed into law on May 13, 2025. If you sell packaged products in Maryland, you need to act before July 1.

Who This Affects

You are likely a "producer" under this law if your company:

• Manufactures products sold in Maryland under your own brand
• Imports packaged products into Maryland for sale
• Licenses your brand to companies that sell in Maryland
• Sells directly to Maryland consumers through your own retail storefront or e-commerce

Small Producer Exemption: Companies that introduced less than 1 ton of covered material into Maryland, or that have global gross revenues under $2 million, are exempt.

Note for repair shops and professional-channel distributors: Packaging for products not sold or supplied to the consumer for personal, noncommercial use is not considered a covered material. If you sell parts exclusively through the professional channel and that packaging never reaches a consumer, it may not be covered. Consult your legal advisor to confirm your status.

The Immediate Deadline: July 1, 2026

Producers must register with the Maryland Department of the Environment (MDE) by July 1. You can register through the Circular Action Alliance (CAA) portal or directly as an individual producer. Maryland allows multiple PROs to operate, so CAA is not your only option.

Key Milestones After July 1

• July 1, 2027: MDE publishes a statewide list of covered materials determined to be recyclable or compostable through curbside programs.
• July 1, 2028: Producers must submit a 5-year Producer Responsibility Plan to MDE and begin covering recycling costs through registration fees.
• Oct. 29, 2028: Sales ban takes effect. Producers without an approved plan on file cannot sell, distribute, or import covered packaging materials in Maryland.
• July 1, 2029: Detailed annual reporting begins.

Covered Materials

The program covers primary and secondary consumer-facing packaging across eight material categories: paper/fiber, rigid plastic, flexible plastic, glass and ceramics, metal, wood and other organic materials, compostable materials, and multimaterial packaging. Purely business-to-business packaging is not covered.

Questions?

Contact MDE's Resource Management Program directly at mde.epr@maryland.gov or 410-537-3314. For general questions about how this program affects your business, contact GovernmentAffairs@autocare.org.