Extended producer responsibility for packaging in United States of America - Colorado

Colorado has adopted a packaging EPR framework called the Producer Responsibility Program for Statewide Recycling (often referred to as Colorado’s “Producer Responsibility Program”). It requires obligated producers of packaging material supplied in/into Colorado to participate in the program (typically via a Producer Responsibility Organization, or PRO) and fund recycling collection, transportation, and processing services statewide. This is a key part of United States of America packaging recycling policy and a flagship example of EPR packaging United States of America in practice. The environmental authority overseeing the program is Colorado Department of Public Health and Environment (CDPHE) EPR.

Who must register for EPR Colorado

You must participate if you are the “producer” of covered packaging material sold or distributed in/into Colorado and you don’t qualify for an exemption. Colorado uses an order-of-obligation approach (who counts as the producer depends on branding, importing, and how the product is sold). In general, the producer is the brand/manufacturer first, and if they are not able to meet the definition, the obligation can shift to the importer/first distributor. Special rules apply for products sold via an internet transaction and for shipping/transport packaging supplied to a covered entity (e.g., packaging used to ship goods to Colorado households).

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What the package includes

For Colorado packaging EPR, the scope centers on “packaging material” used for single or short-term use and used for containment, protection, handling, or delivery of products to the consumer at the point of sale (including via online sales). Packaging also includes certain items supplied for food or beverage consumption that are typically disposed after short-term use and not designed for reuse/refill. Packaging can be made of paper, plastic, glass, metal, cartons, flexible foam, rigid packaging, or combinations.

Key packaging-related exclusions include (among others):

• Transport/distribution-only packaging used solely to ship to nonconsumers (and certain business-to-business packaging not intended for the end consumer)

• Packaging not sold/distributed to covered entities or used for products sold outside Colorado

• Certain excluded “covered materials” categories (e.g., long-term durable-product storage/protection packaging intended to last at least five years; certain regulated product packaging categories listed in law)

Threshold

A producer is generally exempt if it meets any of the statutory exemptions—commonly:

• Revenue exemption: below Colorado’s CPI-adjusted “producer exemption dollar limitation” for the prior calendar year (the base is $5,000,000 and is adjusted periodically)

• Tonnage exemption: used less than one ton of covered materials for products sold/distributed within or into Colorado during the prior calendar year

Additional exemptions include certain nonprofits, state/local government, certain agricultural employers (under specific conditions), certain retail food establishments licensed at a physical location, and certain builders/construction contractors. (Packaging-only note: the tonnage/revenue tests are tied to “covered materials,” so you’ll typically assess them using your packaging + any other covered materials you supply in/into Colorado.)

EPR registration procedure in Colorado

For most obligated companies, compliance is achieved by joining the approved PRO and completing the PRO onboarding + reporting steps. A high-level workflow:

1. Determine obligation: confirm whether you are the “producer” for the packaging you supply into Colorado (and whether any exemption applies).

2. Choose compliance route:

   • Join the designated PRO (most common), or

   • Pursue an approved Individual Program Plan (IPP) if applicable (less common and more complex).

3. Register with the PRO: complete PRO registration, sign required agreements (e.g., participant agreement and any Colorado addendum), and set up your reporting account. This step is often how businesses operationalize EPR registration United States of America obligations in Colorado.

4. Submit supply (packaging) data: report the quantities/weights of packaging supplied into Colorado using the PRO’s reporting formats and timelines.

5. Pay dues/fees: pay annual producer responsibility dues set by the PRO (typically invoiced based on your reported supply data and the PRO’s approved funding mechanism).

6. Maintain records: keep documentation supporting your producer status, exemption (if any), and reported supply data.

Authorized representative

Colorado’s packaging EPR framework does not generally impose a standalone “local authorized representative” requirement in the way some non-U.S. EPR regimes do. In practice, producers commonly appoint an internal owner (or a third-party compliance provider) to act as their operational point of contact with the PRO and to manage reporting and documentation.
Important practical point: if a brand owner/manufacturer is outside the U.S. or otherwise not the obligated “producer” under Colorado’s order-of-obligation, the obligation can shift to the importer/first distributor (so many non-U.S. brands end up being covered through their U.S. importer/distribution structure rather than via a formal “authorized representative” concept).

Reporting

Obligated producers must provide supply data to the PRO (typically covering packaging material weights by material category and other attributes required for fee setting). Reporting is used to calculate your dues and to support statewide performance targets and program planning. Producers should also be prepared to substantiate:

• Methodology used to calculate packaging weights/supply

• Brand lists and corporate relationships relevant to obligation

• Exemption support (if claiming exempt)

• Records sufficient for inspection/audit purposes (as required by program rules)

Deadline

Colorado’s key compliance deadlines (packaging-focused) include:

• Sales prohibition date: after a specified date, producers must not sell or distribute products using covered materials in Colorado unless participating in the program (via PRO or IPP).

• Initial onboarding/reporting milestones: Colorado program guidance sets specific near-term dates for executing producer agreements and submitting supply reports (notably for the startup phase).

• Dues payment timing: producer responsibility dues are due starting in the first program payment cycle and then annually thereafter (exact invoicing/payment timing is set by the PRO within the regulatory framework).

Duties of Each Group Who Is Responsible

• The legal responsibility to comply sits with the obligated producer (as determined by Colorado’s producer definition and order-of-obligation). Participation is usually fulfilled by joining the PRO, but the producer remains responsible for ensuring it is properly registered, reported, and paid.

Duties of each group

• Producers: determine obligation; register/participate; submit accurate packaging supply data; pay dues; keep records; cooperate with audits/inspections as required.

• PRO (Producer Responsibility Organization): runs the program consistent with the approved plan; sets and collects dues; funds and coordinates recycling services; develops lists like the Minimum Recyclable List framework; reports program performance and implements education/outreach.

• CDPHE (environmental authority): oversees and enforces program requirements; approves plans; monitors compliance; can take enforcement action for violations.

• Who is responsible (quick rule)? If you put packaged goods into the Colorado market under your brand (or you are otherwise the obligated party under the order-of-obligation), you are responsible—either directly through the PRO pathway or via an approved IPP.

Additional Information for Consideration

• You cannot “fee-line-item” it: Colorado rules restrict charging consumers a point-of-sale/point-of-collection fee to recoup compliance costs—plan pricing and internal cost recovery strategies should account for this.

• Packaging vs. B2B: a common scoping pitfall is assuming all transport packaging is covered. Colorado’s definition excludes certain packaging used solely in transportation/distribution to nonconsumers and certain B2B-only scenarios—map your packaging flows carefully (e-commerce shipping materials are often treated differently than pure B2B transit packaging).

• Material-level eco-modulation: Colorado’s PRO dues schedules can differentiate costs by material type and recyclability status (e.g., whether a material is on the Minimum Recyclable List vs. not collected), which can materially affect fees and packaging design decisions.

• Startup-phase timing: early program years often have special timelines (data years, report dates, program years may be offset). Build internal timelines so your packaging data (weights, SKUs, bill of materials) is ready ahead of reporting windows.

Extended producer responsibility for packaging in United States of America (Maine)

Maine has established a statewide packaging stewardship framework (often referred to as packaging EPR) that shifts eligible municipal recycling and waste-management costs for packaging material from municipalities to obligated producers through a contracted Stewardship Organization (SO) overseen by the Maine Department of Environmental Protection. This program is a leading example of EPR United States of America and EPR packaging United States of America, supporting United States of America packaging recycling goals via producer-funded reimbursements and eco-modulated fees administered under Maine Department of Environmental Protection (Maine DEP) EPR.

Who must register for EPR in Maine

In Maine, the obligated “producer” is determined by a statutory order-of-obligation that differs depending on how the product is sold:

• Products sold at physical retail in Maine: the obligation generally starts with the party that manufactures the product when sold under the manufacturer’s brand (or when the packaging does not identify the brand), then may shift (if applicable) to a licensed manufacturer selling under another’s brand, then to the legal brand owner, then to the importer of record into the U.S. (when no obligated party has a U.S. presence), and finally to the first distributor into Maine.

• Internet/remote sales into Maine: the producer rules distinguish between (a) packaging that directly contains/protects the product (generally following the same order-of-obligation as above) and (b) packaging that does not directly contain/protect the product (the party that packages the item for delivery to the consumer may be obligated for that delivery/shipping packaging).

• Repackers/fulfillment: a party that adds packaging to another producer’s product for direct distribution to a Maine consumer can be treated as a producer for that added packaging pathway.

• Contractual assignment: Maine allows a producer to assign responsibility to another party via a signed agreement, provided the assignee registers with the SO and provides written certification of the assignment.

What the package includes

Maine’s program applies to “packaging material” used for the containment, protection, delivery, presentation, or distribution of a product—including products sold over the internet—at the point the product leaves a point of sale with, or is received by, the consumer.

Key statutory exclusions (high-level) include:

• Material intended for long-term storage/protection of a durable product expected to remain usable for at least 5 years.

• Beverage containers covered under Maine’s bottle bill framework.

• Architectural paint containers covered under Maine’s paint stewardship program (subject to specific conditions).

• Any additional categories excluded by Maine DEP through rulemaking authority.

Threshold

Maine distinguishes low-volume producers and provides simplified reporting/fee options:

• Low-volume producer: produces less than 15 tons of packaging material in total in/into Maine during the prior calendar year (simplified reporting pathway).

• Low-volume flat-fee option: Maine’s framework provides for a flat-fee option for low-volume producers capped at no more than $500 per ton and no more than $7,500 total annual fees (as structured through the payment schedule framework).

• Perishable food packaging carve-out: Maine includes an exemption related to the first 15 tons of packaging material used by a producer for perishable food sold/distributed in/into Maine during the prior calendar year (with conditions and potential information requests by the department).

EPR registration procedure in United States of America (Maine)

Typical compliance steps for EPR registration for Maine packaging:

1. Determine producer status (physical retail vs internet/remote sales; brand owner vs importer/first distributor; delivery/shipping packaging obligations).

2. Confirm threshold status (low-volume <15 tons; evaluate any applicable exemptions such as the perishable food carve-out).

3. Register with the Stewardship Organization (SO) contracted by Maine DEP (or register through an authorized third-party reporter, if used).

4. Submit required producer information (contact, brands, and—where relevant—packaging pathways).

5. Report packaging supply data (annually; low-volume producers may report simplified totals).

6. Pay required fees (including start-up registration fees and annual producer payments per schedule/invoicing).

7. Maintain records supporting producer determination, quantities reported, and any certifications used for fee adjustments.

Authorized representative

Maine does not use a classic “authorized representative” concept as a universal legal requirement for out-of-state producers. Instead:

• A producer may authorize a third party to report on its behalf (the rules require providing third-party contact info when used).

• For non-U.S. brands with no U.S. presence, producer responsibility may shift to the importer of record (or, if needed, the first distributor) under Maine’s order-of-obligation.

Reporting

Maine requires producers to report packaging material placed in/into Maine to the SO on an annual basis. Key points:

• Annual deadline: producers (including low-volume producers) report by May 31 each year.

• Data scope: rules describe reporting by packaging material type and related attributes; low-volume producers can report total tons (and may optionally report by type and additional attributes).

• UPC reporting note: Maine statute provides that producers may not be required to report packaging using product UPCs; Maine DEP has also signaled rule updates to align Chapter 428 with statutory changes. In practice, producers should follow the current SO reporting guidance aligned with the latest DEP direction.

• Auditing/quality assurance: the SO conducts quality assurance and can audit producer reporting; the department can also request audits if reporting is suspected to be inaccurate.

Deadline
Maine’s implementation timeline (program milestones commonly referenced by Maine DEP communications) includes:

• Spring 2026: Maine DEP contracts with the SO.

• May 2026: producers register with the SO and submit initial reporting (described as an estimate for the prior year in DEP materials).

• July 2026: SO invoices producers for start-up registration fees (to cover initial start-up operational costs).

• September 2026: producers pay the start-up registration fee (timed to be no more than 180 days after the SO contract effective date).

• May 2027: producers report packaging placed in/into Maine during calendar year 2026.

• September 2027: producers make the first annual payment for packaging placed in/into Maine during calendar year 2026.

• October 2027: participating municipalities receive the first reimbursements for costs from calendar year 2026.
  Also, Maine includes a sales prohibition mechanism: beginning one calendar year after the SO contract effective date, a producer generally may not sell/distribute products in/into Maine using packaging material unless compliant with program requirements.

Duties of Each Group Who Is Responsible

• The legally obligated producer (as determined by Maine’s producer definition and order-of-obligation) is responsible for compliance, even when using a third-party reporter.

Duties of each group:

• • Producers: determine obligation; register; report packaging supply data; pay start-up and annual fees; maintain documentation; support audits/verification as required.

  • Stewardship Organization (SO): administers the program under contract with Maine DEP; collects producer payments; manages the packaging stewardship fund; performs quality assurance/auditing mechanisms; reimburses participating municipalities; supports investments in recycling infrastructure and education as authorized.

  • Maine DEP (environmental authority): selects/contracts the SO; adopts/updates implementing rules; oversees compliance/enforcement and program governance.

  • Participating municipalities: opt into the program (participation is voluntary) and provide required cost and program data to receive reimbursements.

• Who is responsible (quick rule)? If you place packaged goods into the Maine market under your brand—or you are the obligated party under Maine’s producer hierarchy (including certain delivery/shipping packaging in remote sales)—you are responsible for Maine packaging EPR compliance.

 Additional Information for Consideration

• Eco-modulated fees (design incentives): Maine’s framework is designed to adjust fees to incentivize environmentally preferable packaging characteristics (e.g., recyclability and lower toxicity).

• Toxics certificate impact: Maine rules include additional fees when a producer cannot provide supplier certification attesting to no intentional addition of toxics for a packaging material type.

• Labeling/recyclability-claim risk: rules include fee consequences for packaging labeled as recyclable/reusable/compostable when the corresponding management pathway is not available statewide (or does not meet rule conditions).

• Alternative collection programs: producers (or groups of producers) may propose alternative collection programs for certain packaging types; qualifying performance can offset payment obligations for the same packaging material type, subject to approval and reporting.

• Keep an eye on Chapter 428 updates: Maine has been actively aligning its rules to statutory amendments (including changes affecting UPC reporting expectations). Build compliance processes that can adapt to the most current DEP/SO guidance.

Extended producer responsibility for packaging in United States of America - Maryland

Maryland has adopted a statewide Extended Producer Responsibility program for packaging (often referred to as EPR United States of America) through Senate Bill 901 (Chapter 431, signed May 13, 2025; effective June 1, 2025). The program shifts the financial and operational responsibility for managing packaging waste (collection, transport, processing, recycling/composting, education, and system improvements) from local governments/taxpayers to “producers” of covered packaging. This Maryland program is administered by the Maryland Department of the Environment (Maryland Department of the Environment (MDE) EPR).

Who must register for EPR in Maryland

In Maryland, the obligation applies to “producers” of covered packaging sold, offered for sale, imported, or distributed into the State. In practice, compliance is handled either by:

• Participating in the State-approved Producer Responsibility Organization (PRO),

• Submitting an individual Producer Responsibility Plan (an “independent” plan) directly to MDE.

For packaging that directly protects or contains a product, the “producer” is determined through a hierarchy (e.g., brand owner; or manufacturer if no brand; or licensee; or importer if no upstream entity exists). For e-commerce shipments, responsibility is split so that

• Product packaging follows the same producer rules as above
• Shipping packaging is assigned to the entity that packages the item to be shipped to the consumer.

What the package includes

For Maryland’s EPR packaging United States of America framework, “packaging materials” broadly includes:

• Primary, secondary, and tertiary packaging intended for the consumer market

• Service packaging filled at point of sale (including carry-out bags, bulk goods bags, and take-out/home-delivery food service packaging)

• Beverage containers (as defined in the law), unless covered under a beverage container deposit return program (if enacted in Maryland)

Packaging scope also includes specific exclusions (i.e., items that are not treated as “packaging materials” under the statute). These exclusions include certain regulated/health-and-safety related packaging categories and other carve-outs specified in the law.

Threshold

Maryland defines a “de minimis producer” (exempt from being treated as a producer under this EPR framework). You are de minimis if, in your most recent fiscal year, you either:

• Introduced less than 1 ton of covered material into Maryland, or

• Earned global gross revenues of less than $2,000,000

If you qualify as de minimis, you generally do not need to participate in the program as a producer.

EPR registration procedure in Maryland

For Maryland, registration/participation is operationalized through the PRO model plus plan submission requirements:

1. MDE approval of a single PRO: MDE must approve a single Producer Responsibility Organization to fulfill the initial PRO role for the program.

2. PRO registration with MDE (annual): Beginning July 1, 2026, and each year thereafter, the approved PRO must file a registration form with MDE that includes, among other items, lists of participating producers, brands, and covered materials, plus a compliance contact person.

3. Producer Responsibility Plan submission (every 5 years): On or before July 1, 2028 (and every 5 years thereafter), each producer must submit a Producer Responsibility Plan either individually or as part of the PRO. Producers/PRO must consult with the Advisory Council before submitting the plan to MDE.

4. Statewide recyclable/compostable list: On or before July 1, 2027, MDE must develop a statewide list of covered materials determined to be recyclable or compostable through curbside recycling programs (used to shape program requirements, targets, and fee signals).

5. Fees and eco-modulation: The PRO’s fee structure is designed to vary based on system costs and can include eco-modulated fees (e.g., higher fees for low-recyclability packaging, discounted fees for higher-recyclability/recycled-content packaging), supporting United States of America packaging recycling outcomes in Maryland.

Authorized representative

Maryland’s packaging EPR framework does not operate like “authorized representative” concepts seen in some non-US jurisdictions. Instead, Maryland uses two practical delegation mechanisms:

• PRO participation: Producers may comply through membership in the PRO (the PRO administers the plan and program obligations on behalf of participating producers).

• Assumption by agreement (written certification): The law allows a producer to execute an agreement where another entity agrees to assume responsibility (by written certification) for packaging materials attributable to the producer—this is relevant for corporate structures, contracting models, and certain brand/distribution arrangements.

Reporting Deadline

Key Maryland reporting/filing dates include:

• By June 30, 2025: MDE approval of a single PRO (initial designation).

• Starting July 1, 2026 (annual): PRO registration filing with MDE (includes producer/brand/material lists and compliance contact).

• By July 1, 2027: MDE statewide list of recyclable/compostable covered materials through curbside programs.

• By July 1, 2028 (every 5 years): Producer (or PRO on producers’ behalf) must submit a Producer Responsibility Plan to MDE.

• Starting July 1, 2029 (annual): Each producer or PRO with an approved plan must report annually to MDE on progress for the immediately preceding calendar year.

Who Assumes Responsibility?

Responsibility is assigned primarily to the “producer,” but the responsible party depends on how the product/packaging enters Maryland:

• Retail/standard distribution: Usually the brand owner or manufacturer (per the statutory hierarchy), with fallbacks to licensee, importer, or first distributor into the State if no upstream entity exists in the U.S.

• E-commerce shipping:

  • Product packaging responsibility follows the producer hierarchy; and

  • Shipping/transport packaging is the responsibility of the entity that packages the item for shipment to the consumer.

• Delegated responsibility: A producer can shift responsibility to another entity through a qualifying written certification agreement (where permitted and correctly structured).

Duties of Each Group

• Producers (individually or via PRO): Join/participate and fund the system, ensure a compliant plan is submitted on time, meet program requirements/targets through the approved plan, and support reporting/auditing obligations.

• Producer Responsibility Organization (PRO): Registers annually with MDE, develops/implements the Producer Responsibility Plan, administers fees (including eco-modulation), reimburses eligible service provider/local government costs as defined in the plan, conducts education/outreach, supports end-market requirements, and submits required reporting.

• Maryland Department of the Environment (MDE): Approves the PRO and producer plans, adopts implementing regulations, develops the statewide recyclable/compostable list, oversees enforcement, and publishes nonconfidential program reporting.

• Advisory Council: Reviews plans and annual reports and provides written recommendations to inform MDE decisions and plan development.

• Service providers / local governments: Continue operations for collection/processing and may seek reimbursement and participate in plan development, standards, and data/reporting processes as established.

Who Is Responsible

In Maryland, the legally responsible party is the producer (unless exempt as de minimis or otherwise excluded), with compliance fulfilled either through:

• The PRO (most common compliance pathway), or

• An independent producer plan submitted directly to MDE.

This is the practical compliance interpretation for EPR registration United States of America when applied at the state level in Maryland.

Additional Information for Consideration

• Enforcement and penalties: Maryland provides for escalating penalties for violations (with notice and cure provisions for producers) and additional penalties tied to failure to achieve performance goals (applied to the PRO).

• Confidentiality vs. transparency: Certain financial/production/sales data reported to MDE must be kept confidential, while program reports (subject to confidentiality limits) are intended to be posted publicly.

• Implementation is regulation-heavy: MDE must adopt regulations to carry out the program; early compliance planning should track MDE rulemaking, guidance, and PRO onboarding requirements.

• Packaging exemptions by request: Producers may be able to request that MDE classify certain packaging types as exempt if specific federal/state health and safety requirements prevent waste reduction or recyclability/compostability (subject to process and time limits).

• Program scope note (this guide): Maryland’s law covers packaging and paper products; this guide intentionally focuses only on packaging.

Extended producer responsibility for packaging in United States of America - Minnesota

Minnesota has a statewide packaging Extended Producer Responsibility (EPR) framework called the Packaging Waste and Cost Reduction Act (Minn. Stat. §§ 115A.144–115A.1463). It shifts the cost (and many program responsibilities) for managing packaging waste from residents/local governments to “producers” that place packaging on the Minnesota market. This supports United States of America packaging recycling outcomes like more consistent collection lists, better access to recycling/composting, and incentives to reduce packaging waste.

Who must register for EPR in United States of America - Minnesota

For Minnesota, a “producer” must comply if they introduce covered packaging into Minnesota (including via e-commerce/remote sales). In practice, the responsible producer is determined by a hierarchy (manufacturer → licensed manufacturer → brand owner → importer of record → first distributor), with special rules for e-commerce shipping packaging.
Key point for compliance planning: if you sell packaged goods into Minnesota, you should assume you may have obligations under EPR United States of America / EPR packaging United States of America unless you clearly fall into an exemption (see Threshold section).

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What the package includes

Minnesota’s EPR program applies to packaging (as defined in Minnesota law) and also treats packaging as “covered material” under the Act. “Packaging” is broadly defined and includes common packaging components and shipping/transport elements (e.g., containers and appurtenant materials used to transport/market/protect/handle a product, and items like pallets, blocking/bracing/cushioning, strapping, coatings, closures, inks, dyes/pigments, labels, etc.).
The Act’s broader scope also references food packaging and paper products, but this guide is focused only on packaging.

Threshold

Minnesota includes a de minimis producer exemption. A business is typically exempt as a de minimis producer if, in its most recent fiscal year, it either:

• introduced less than one ton of covered material into Minnesota; or

• earned global gross revenues under $2,000,000.

There are also scope limits/exclusions in the law for certain types of packaging (e.g., specific health/medical-related packaging categories, certain hazardous/flammable product packaging where requirements prevent redesign, packaging already managed under certain other stewardship plans, and other listed exclusions). These exclusions can be very fact-specific, so companies should map their packaging formats against the statutory “exempt materials” list if they believe an exclusion applies.

EPR registration procedure in United States of America Minnesota

Minnesota is administered by the state environmental authority, and producers comply by joining a registered Producer Responsibility Organization (PRO). The current initial PRO confirmed by the state is Circular Action Alliance (CAA). Practical steps:

1. Confirm producer status: Determine whether you are the “producer” under Minnesota’s hierarchy (brand owner/manufacturer/importer/first distributor; special rules for e-commerce shipping packaging).

2. Check exemptions: Confirm whether you qualify as a de minimis producer or whether your packaging falls within an “exempt materials” category.

3. Register with the PRO: Producers must be members of a PRO registered with the state (Minnesota’s initial PRO is CAA). This is the operational step most companies treat as “registration.”

4. Submit required data & maintain membership: Be ready to provide packaging data needed for fee setting and program performance (often by material type/weight and supply-chain role), and keep membership active.

5. Prepare for the next compliance phase (2029+): After January 1, 2029, producers generally may not introduce covered materials unless they have a written agreement with a PRO to operate under an approved stewardship plan.

Authorized representative

Minnesota does not use a classic “authorized representative” model the way some jurisdictions do. However, the law allows responsibility to be contractually assigned in certain situations: if another person has a mutually signed agreement with the producer that assigns producer responsibility, that party can act as the responsible producer as long as they join the registered PRO for the relevant covered material and provide the required certification to the PRO.
Practically, this can be used in supply chains where responsibility is centralized (e.g., a brand owner assigning compliance to a designated entity).

Reporting

In Minnesota, much of formal reporting flows through the PRO, but producers must still provide accurate data to support:

• fee calculation and eco-modulation (where applicable under the program design),

• performance tracking by covered materials type, and

• verification/auditing processes required under the stewardship plan.

The PRO has an annual reporting duty to the state beginning in 2029 (and annually thereafter), covering items like quantities introduced by material type, progress against performance targets, and other required metrics. Producers should expect the PRO to set schedules/templates for producer data submission well before statutory reporting dates.

Deadline

Key statutory timing triggers for packaging EPR in Minnesota include:

• After July 1, 2025: Producers must be a member of a producer responsibility organization registered in Minnesota (this date has already passed as of today).

• After January 1, 2029: Producers generally may not introduce covered materials unless operating under a written agreement with a PRO to operate under an approved stewardship plan.

• By July 1, 2028: The state must develop statewide lists of what is considered recyclable/compostable (and an alternative collection list) to support consistent statewide systems.

• After January 1, 2032: Producers may not introduce covered materials unless covered services are provided under an approved stewardship plan and the covered materials meet required conditions (e.g., reusable/refillable, or included on the state’s recyclable/compostable lists), subject to possible extensions for specific materials.

• PRO annual report: Due April 1, 2029, and annually thereafter.

Who Assumes Responsibility

Responsibility hinges on who is legally defined as the “producer” for the packaging being introduced into Minnesota:

• Retail (in-state physical locations): typically the product manufacturer or brand owner (depending on which entity meets the hierarchy).

• Remote sales / e-commerce:

  • For packaging that directly protects/contains the item: generally the same producer as the packaged item.

  • For shipping packaging used to ship the item to a consumer: the producer is typically the person/entity that packages the item for shipment to the consumer.

• If no responsible entity in the U.S.: the importer of record into the U.S. can become the producer.

• If still unresolved: the “first distributor” into Minnesota may be responsible.

• Contractual assignment: Another party can assume responsibility by contract (with required certification and PRO membership).

Duties of Each Group

• Producers

  • Join the registered PRO and remain in good standing.

  • Pay producer fees.

  • Comply with the stewardship plan requirements and other statutory obligations (including future constraints on what may be introduced after 2029/2032).

• Producer Responsibility Organization (PRO) (e.g., CAA)

  • Register with the state, administer the program, collect fees, and reimburse service providers according to the plan.

  • Maintain required public information (e.g., program website) and submit required reports to the state.

  • Help ensure producer compliance (including expulsion/notification processes when needed).

• Service providers (e.g., local governments/haulers/material management entities participating in the plan)

  • Register as required, provide covered services consistent with the stewardship plan, and meet program conditions to receive reimbursements/funding.

• State oversight (the “commissioner” / environmental authority)

  • Oversee and enforce the program, approve PRO registration and stewardship plans, conduct needs assessments, and publish statewide recyclable/compostable lists.

  • This role is commonly referred to in guidance as Minnesota Pollution Control Agency EPR oversight (MPCA is the relevant agency).

Who Is Responsible

A quick way to decide “who is responsible” for packaging EPR in Minnesota:

• If your company owns the brand on the packaged product sold into Minnesota → you are often the producer.

• If you manufacture the packaged product (especially if packaged under your own brand) → you may be the producer.

• If you import packaged goods into the U.S. and sell into Minnesota where no other U.S. producer applies → you may be the producer.

• If you fulfill and package e-commerce orders using shipping materials to send to Minnesota consumers → you may be the producer for that shipping packaging.

• If you’re a small business under the de minimis thresholds → you may be exempt, but confirm carefully.

Additional Information for Consideration

• If you haven’t registered yet: Since the July 1, 2025 membership requirement has passed, producers that are newly discovering obligations should treat this as an urgent compliance gap and register with the PRO as soon as possible.

• Cost coverage ramps up: The law phases in reimbursement of service providers’ net costs (commonly summarized as 50% by 2029, 75% by 2030, and at least 90% by 2031 and beyond). This can materially affect producer fees over time.

• Statewide “what’s recyclable/compostable” lists matter: By 2028 the state lists will heavily influence what packaging formats can continue to be introduced after 2032 (unless reusable/refillable systems apply or an extension is granted). Packaging design teams should track these developments early.

• Broader compliance ecosystem: Minnesota packaging compliance may intersect with other Minnesota restrictions (e.g., toxics/PFAS-related rules affecting packaging materials). Even if you’re focused on EPR, align packaging specifications with broader state requirements to avoid redesign twice.

Extended producer responsibility for packaging in United States of America - Oregon

Oregon’s packaging EPR framework is part of the Plastic Pollution and Recycling Modernization Act (also referred to as the Recycling Modernization Act / SB 582). It modernizes the state’s recycling system and shifts key costs to producers through a Producer Responsibility Organization (PRO), supporting United States of America packaging recycling goals. The program is overseen by Oregon Department of Environmental Quality (DEQ) EPR and operationalized through the approved PRO (currently Circular Action Alliance). This is a core state program within EPR United States of America and EPR packaging United States of America.

Who must register for EPR in United States of America - Oregon

If you are the “producer” of packaging supplied in or into Oregon, you must comply (unless exempt as a small producer or your packaging qualifies for a covered product exemption). Oregon assigns “producer” responsibility through an order-of-obligation that commonly results in:

• The brand/manufacturer (including certain licensee arrangements) being responsible for the product packaging, and

• The entity that packages and ships an item to an Oregon consumer being responsible for shipping/fulfillment packaging (with a duty to notify the product-packaging producer in certain remote-sale scenarios).
  If there is no responsible producer in the United States for the packaged item, the importer (and in some cases the first distributor into Oregon) can become the obligated producer.

• Ready to make extended producer responsibility effortless for USA? Request a personalized EPR fee quote now and start turning regulatory obligations into sustainable value for your brand for cross-border sales!

What the package includes

For Oregon packaging EPR, “packaging” generally covers items used for the containment or protection of products—including single-use bags and certain non-durable materials used in storage/shipping/moving (e.g., packing materials, moving boxes, file boxes or folders). Packaging is treated as a “covered product” unless an exemption applies. (This guide is packaging-only; Oregon’s law also covers other covered products, but those are out of scope here.)

Threshold

Oregon has a small producer exemption that removes the obligation to register, report, or pay fees when you qualify as a small producer (there are multiple statutory pathways to qualify). Commonly cited thresholds include:

• Global gross revenue of USD 5 million or less, or

• Less than 1 metric ton of covered products supplied in/into Oregon in a year.
  Separately, Oregon also recognizes covered product exemptions (product/packaging-type exemptions) that remove certain packaging from the definition of “covered product,” which can reduce reporting and fees for those exempted materials.

EPR registration procedure in United States of America (Oregon)

1. Determine whether your materials are “packaging” covered by the program and whether you are the obligated producer under Oregon’s producer hierarchy.

2. If you are obligated (and not exempt), register with Oregon’s approved PRO (Circular Action Alliance).

3. Sign the required participation agreement(s) (CAA requires a Producer Participant Agreement and Oregon-specific addendum to access its reporting portal).

4. Submit required supply reporting to the PRO using the PRO’s methodology and categories (Oregon’s first required reporting cycle covered 2024 supply data).

5. Pay producer membership fees as invoiced by the PRO (fee rates are allocated based on producer supply and change over time; timely reporting is critical).

Authorized representative

Oregon does not generally use a standalone “authorized representative” model for packaging EPR. In practice, producers typically designate an internal compliance contact (or a third-party compliance provider where allowed by the PRO’s processes) to manage EPR registration United States of America obligations for Oregon and coordinate reporting, agreements, and invoicing with the PRO.

Reporting

Obligated producers must report packaging supplied in or into Oregon to the PRO using the reporting approach established by the PRO and Oregon’s rules/guidance. Reporting is used to calculate market share and allocate fees.
For remote sales, where an entity is only the producer of shipping/fulfillment packaging, it may also need to notify the producer responsible for the product packaging (and that producer’s PRO) about the sales into Oregon so the product-packaging producer can meet obligations.

Deadline

Key Oregon packaging EPR dates include:

• Law effective date: January 1, 2022.

• Recycling system changes and PRO program implementation: starts July 2025.

• Producer pre-registration / initial supply reporting: producers intending to sell covered products on/after July 1, 2025 were required to pre-register and submit 2024 supply data by March 31, 2025 (small producers excluded; late reporting was encouraged during a grace period that ran to April 30, 2025).

• First program plan period: July 1, 2025 through December 31, 2027 (2025–2027 program years).

Duties of Each Group Who Is Responsible

The legally obligated producer (as determined by Oregon’s producer hierarchy) is responsible for compliance, typically by participating in the approved PRO.

Duties of each group

• • Producers: join the approved PRO (unless exempt), report packaging supply data, and pay fees.

  • PRO (Circular Action Alliance): administers the producer responsibility program under its DEQ-approved plan (including fee setting/collection and system funding actions).

  • Oregon DEQ (the environmental authority): approves and oversees the program plan, maintains program guidance/updates and rulemaking, and enforces compliance.

• Who is responsible (quick rule)? Brand/manufacturer/licensee/importer/distributor responsibility applies for product packaging (depending on how your products are sold and whether a U.S. entity exists in the chain).

  • The party that packages and ships an item to an Oregon consumer is typically responsible for shipping packaging used for that remote sale.

Additional Information for Consideration

• Penalties: Oregon may assess civil penalties for non-compliance, with a statutory maximum of $25,000 per day (actual penalty depends on factors set in administrative rule).

• Private recycling exemption (limited): producers may claim an exemption for certain materials recycled outside the “opportunity to recycle” system if they meet specific criteria (private collection, no commingled MRF separation, recycled at a responsible end market) and follow DEQ’s claims process/timing.

• Rulemaking and plan amendments: Oregon continues to refine program rules and review plan amendments (important for compliance teams managing EPR packaging United States of America requirements across states). Track DEQ updates and PRO guidance for any changes to reporting, exemptions, and responsible end-market requirements.

Extended producer responsibility for packaging in United States of America

Washington State has adopted a packaging EPR framework through the Recycling Reform Act (SB 5284), creating an extended producer responsibility program for residential packaging (and certain paper products). The program is overseen by the Washington State Department of Ecology and is designed to shift the cost of managing packaging waste from residents/local governments to producers, while expanding and standardizing recycling statewide. This is a key development for EPR United States of America and EPR packaging United States of America compliance planning, especially for brands selling into Washington.

Who must register for EPR In Washington State

In Washington, the “producer” responsible for packaging compliance is generally the brand/manufacturer tied to the product sold into the state, using a legal “producer hierarchy.” For e-commerce, responsibility can extend to the party that packages an item for shipment to the consumer (for shipment packaging).
Washington also excludes certain entities from being considered “producers” (for example, de minimis producers and certain organizations), and allows limited contractual assignment of producer responsibility (see “Authorized representative”). This is central to EPR registration United States of America scoping for Washington.

Ready to make extended producer responsibility effortless for USA? Request a personalized EPR fee quote now and start turning regulatory obligations into sustainable value for your brand for cross-border sales!

What the package includes

For Washington’s packaging EPR program, “packaging” is broadly defined as material used to protect, contain, transport, serve, or facilitate delivery of a product and that is sold or supplied with the product to the consumer for personal, noncommercial use.
“Covered material” includes packaging (and paper products) introduced into Washington, but excludes “exempt materials,” which include multiple regulated packaging categories (notably certain medical/drug-related packaging, some hazardous-product packaging constraints, certain durable-product storage packaging, and other listed exemptions).

Threshold

Washington provides a “de minimis producer” concept that can exempt certain producers from the packaging EPR obligations. A producer may qualify as de minimis if it meets criteria such as introducing less than one ton of covered materials in its most recent fiscal year, and/or meeting specific revenue-based thresholds (including special treatment for certain agricultural employers). If you are evaluating multi-state United States of America packaging recycling obligations, confirm whether your Washington footprint triggers “responsible producer” status (i.e., not de minimis).

EPR registration procedure in in Washington State

Washington’s packaging EPR program is implemented via Producer Responsibility Organization(s) (PROs) with formal registration and planning steps. Key steps include:

• Producers must appoint one or more PROs by January 1, 2026.

• PRO registration with the Washington State Department of Ecology is due by March 1, 2026 (and annually thereafter).

• After July 1, 2026, producers must either (1) be a member of a registered PRO, or (2) register as a PRO to operate under an individual plan.

• Beginning March 1, 2029, producers that are not in good standing with a registered PRO (or operating under an approved individual-plan pathway) may not introduce covered materials into Washington.
  This is the core compliance pathway for Washington Department of Ecology EPR obligations.

Authorized representative

Washington does not use an EU-style “authorized representative” requirement for non-established producers. Instead, Washington relies on:

• PROs registering “on behalf of” their member producers, and

• Limited contractual assignment: another party may assume producer responsibility only if there is a mutually signed agreement assigning responsibility and the assignee joins a registered PRO as the responsible producer for that covered material (with documentation rules and certain ineligible assignees).
  In practice, the PRO structure is the primary compliance vehicle.

Reporting

Washington’s program includes reporting obligations primarily driven through the PRO and its plan. Notable reporting-related milestones include:

• PRO registration submitted annually (starting 2026).

• PRO plan submission to Ecology due by October 1, 2028 (and every five years thereafter).

• PRO annual reporting to Ecology begins later in the rollout: the PRO must submit an annual report by July 1, 2031, and each July 1 thereafter, covering required performance, material, and program information.

Deadline

A practical Washington packaging EPR timeline (selected major dates):

• July 27, 2025: Law effective.

• January 1, 2026: Producers appoint PRO(s).

• March 1, 2026: PRO registration due (annual thereafter).

• July 1, 2026: Producers must be in a registered PRO or pursue an individual plan pathway.

• October 1, 2028: PRO plan due to Ecology.

• March 1, 2029: Market access restriction for noncompliant producers (cannot introduce covered materials).

• By 2030: Statewide, consistent and expanded recycling services begin rolling out; program implementation is tied to plan approval and statutory timing.

Who Assumes Responsibility

Responsibility generally sits with the “producer” defined by Washington’s statutory hierarchy (manufacturer/brand owner/licensee/importer/distributor depending on circumstances). For shipment packaging in e-commerce, the party that packages the item to be shipped to the consumer can be responsible for that shipping packaging. Producers typically discharge obligations by joining a registered PRO, which then operationalizes the system.

Duties of Each Group

• Producers: Join and fund a PRO (or operate an individual plan as a registered PRO), maintain good standing, and meet requirements applicable to the covered packaging they introduce.

• PRO: Registers with Ecology, establishes producer fees, submits the program plan, implements program operations, reimburses eligible system costs per the law, runs education/outreach, supports responsible end markets, and submits required reports.

• Washington State Department of Ecology: Rulemaking, registration oversight, statewide collection list development, needs assessments, plan review/approval, and enforcement.

• Service providers / local governments: Continue providing recycling collection/processing services within the new standardized and funded framework, subject to the program’s requirements and reimbursement mechanics.

Who Is Responsible

If you place packaged goods on the Washington market, assume you are responsible unless you clearly fall into a statutory exemption (such as de minimis status or an exempt material category). For most brands, compliance means joining the designated PRO(s) and ensuring your packaging data and fee obligations are met. If you sell via e-commerce, confirm who controls shipment packaging decisions, because that can shift responsibility for that specific packaging stream.

Additional Information for Consideration

• Washington’s packaging EPR rollout includes rulemaking, statewide recyclable-material lists, and needs assessments before full operational implementation; expect compliance details (data formats, fee methodologies, reporting templates) to become more specific as Ecology finalizes rules and guidance.

• Washington also has separate producer-focused requirements affecting certain plastic packaging (for example, post-consumer recycled content minimums and producer registration/reporting for specific covered plastic product categories). These requirements are not the same as the packaging EPR program, but they can apply in parallel and should be included in a Washington packaging compliance map.

• If you are aligning a national strategy for EPR United States of America, treat Washington as a “packaging EPR state” (with its own definitions, exemptions, and timelines) and avoid assuming another state’s thresholds or reporting logic will transfer cleanly.

Extended producer responsibility for packaging in United States of America in California

California’s EEE (Electrical and Electronic Equipment) EPR is primarily implemented through the Covered Electronic Waste (CEW) Recycling Program under the Electronic Waste Recycling Act, administered by CalRecycle EPR. The program uses a state recycling fee collected at retail on certain covered devices to fund approved collectors and recyclers and provide convenient statewide recycling for eligible electronics.

Who must register for EPR in California

For California EEE, the core “producer” obligation applies to manufacturers of Covered Electronic Devices (CEDs) (generally video display devices) that are sold in California. These manufacturers must comply with CalRecycle’s manufacturer requirements (registration/participation as applicable, plus annual reporting). Retailers also have compliance obligations tied to collecting the California e-waste recycling fee at point of sale.

• Ready to make extended producer responsibility effortless for USA? Request a personalized EPR fee quote now and start turning regulatory obligations into sustainable value for your brand for cross-border sales!

What the package includes

For California EEE, the scope is not “packaging” but Covered Electronic Devices (CEDs). A CED is essentially a video display device with a screen larger than 4 inches (diagonal) that is identified by DTSC regulations as hazardous waste when discarded. Common examples include televisions, monitors, laptops, tablets, and certain portable video display products (when they meet the legal definition).
California is also expanding the program to include covered battery-embedded products (CBEPs) under SB 1215, which are planned to enter the CEW program beginning in 2026 (separate fee mechanics and manufacturer notice/reporting milestones apply).

Threshold

There is no simple “minimum units/tonnage” threshold for the core obligation: if you manufacture (as defined in the law) and sell covered devices into California, you generally fall within the manufacturer requirements for the CEW program.
For CBEPs, manufacturers have additional notice/reporting triggers on the statutory timeline once their products are classified as covered (with exemptions possible by product type).

EPR registration procedure in United States of America

A practical California EEE compliance flow looks like this:

1. Confirm scope: determine whether the products you sell in California meet the definition of a CED (and whether any are CBEPs under the SB 1215 pathway).

2. Manufacturer registration/participation: if you intend to participate as a registered manufacturer in the CEW program, submit CalRecycle’s manufacturer registration application (and any supporting documentation requested).

3. Set up annual reporting: prepare internal data by brand/device category for California sales to complete the manufacturer annual report.

4. Retail readiness (if applicable): ensure retail channels understand when the California Electronic Waste Recycling Fee must be charged and remitted (via CDTFA processes).

5. Ongoing compliance: submit annual manufacturer reporting on time; track SB 1215 milestones for CBEPs if relevant.

Authorized representative

California’s CEW framework does not operate on a classic “authorized representative” model. Instead, responsibility is attached to the legally defined manufacturer (and retailers have separate duties). Practically, non-California or non-US brands typically manage compliance through their entity that qualifies as “manufacturer” under the law and by appointing an internal compliance contact to handle CalRecycle reporting and retailer communications.

Reporting

Key reporting streams include:

• Manufacturer annual report (CEDs / video display devices): manufacturers selling CEDs in California must submit an annual report to CalRecycle covering the prior calendar year.

• Collectors and recyclers: approved collectors/recyclers have DTSC-related annual reporting requirements (separate from manufacturer reporting).

• CBEP pathway (SB 1215): manufacturers must provide annual notices to retailers identifying covered vs exempt battery-embedded products, and CBEP manufacturer reporting begins later on the statutory timeline.

Deadline

• Manufacturer annual report (CEDs/video display devices) due on or before July 1 each year, covering the previous calendar year.

• Collectors/recyclers reporting to DTSC: due before February 1 (per DTSC-related requirements referenced by CalRecycle).

• CBEP (SB 1215) annual manufacturer notice to retailers: begins July 1, 2025 and annually thereafter (identifying covered/exempt products), with a copy provided to CalRecycle.

• California CEW recycling fee (CEDs): current fee tiers remain in effect (by screen size) and are collected at retail; the fee is not a deposit (no redemption value).

• CBEP fee rollout: SB 1215 sets a timeline for establishing the battery-embedded fee for implementation beginning in 2026.

Who Assumes Responsibility

• Manufacturers assume responsibility for manufacturer compliance and annual reporting for covered electronic devices sold in California.

• Retailers assume responsibility for charging the California e-waste recycling fee to consumers at the point of sale (for covered devices) and handling remittance through the state’s fee administration system.

• Consumers pay the fee at purchase.

• CalRecycle administers the CEW program, including overseeing participation and program payments to approved collectors/recyclers.

• DTSC identifies covered devices in regulation and administers related hazardous/universal waste management standards that interact with the CEW system.

Duties of Each Group

• Manufacturers (responsible producers under CEW)

  • Determine whether products sold into California are covered (CED/CBEP).

  • Complete CalRecycle manufacturer registration/participation steps where applicable.

  • Submit the annual manufacturer report by the statutory deadline (and CBEP reports when that phase begins).

  • For CBEPs, send annual notices to California retailers and CalRecycle identifying covered/exempt products.

• Retailers

  • Charge the applicable California CEW recycling fee at retail sale/lease of covered devices (and follow CDTFA guidance for administration).

• CalRecycle (environmental authority / program administrator)

  • Oversees CEW program implementation, publishes manufacturer guidance/forms, and manages program structures supporting approved collectors/recyclers.

• DTSC

  • Defines/maintains the regulatory identification of covered electronic devices as hazardous when discarded, and sets related management standards.

Who Is Responsible

If your company is the manufacturer (as defined under the CEW law) of a covered electronic device sold in California, you are responsible for meeting CalRecycle’s manufacturer requirements (notably annual reporting). If you are a retailer selling covered devices, you are responsible for correctly charging the CEW recycling fee at point of sale and following CDTFA rules for the fee program.

Additional Information for Consideration

• California’s CEW system is fee-funded at purchase (not a “return-for-refund” deposit model), which affects how compliance costs appear at checkout and how businesses communicate fees.

• The SB 1215 battery-embedded product expansion introduces a new compliance track: manufacturers should build an early product-classification process (covered vs exempt) and a repeatable annual retailer-notice workflow.

• Don’t assume “all electronics” are covered: the CEW program is tightly tied to the legal definition of covered electronic devices (primarily video display devices), plus the staged CBEP expansion.

• If you manage multi-state EPR, treat California EEE as its own workstream: it differs structurally from PRO-funded packaging EPR states because California’s CEW program is primarily a state fee and payment system administered through state agencies.

Extended producer responsibility for packaging in United States of America in Colorado

Colorado’s EEE framework is often discussed alongside EPR United States of America, but it is not a classic producer-funded takeback EPR program for electronics. Instead, Colorado regulates end-of-life electronics primarily through the Electronic Recycling Jobs Act (C.R.S. 25-17-301 et seq.), including a statewide landfill disposal ban for electronic devices and requirements affecting recyclers, waste haulers, landfills/transfer stations, counties, and state agencies. Oversight sits with the Colorado Department of Public Health and Environment (CDPHE) EPR functions (Solid & Hazardous Waste / Materials Management).

Who must register for EPR in Colorado

For EEE (electronics) in Colorado, the registration obligation generally applies to electronics recyclers, not manufacturers/brand owners:

• Any site separating, sorting, processing, dismantling, and/or baling waste electronic materials is treated as a recycling facility and must register with CDPHE as a recycler.

• Manufacturers/brand owners do not have a statewide “producer registration” requirement for electronics comparable to packaging EPR programs in other states.

What the package includes

Colorado’s EEE scope focuses on electronic devices (including key subcategories such as “video display devices”). The statute defines “video display device” broadly as devices capable of displaying moving images, and also includes devices with screens 4 inches or larger that contain a tuner and can receive/display TV/video programming, with certain exclusions (e.g., motor-vehicle components).
Practically, this captures many common consumer electronics (TVs, monitors, certain display-equipped devices), and the landfill ban applies to an electronic device or its components.

Threshold

Colorado’s electronics framework is not threshold-based for producers:

• The landfill ban applies statewide (with a limited county exemption process).

• The recycler compliance threshold is activity-based: if a site is performing electronics recycling activities (sorting/processing/dismantling/baling), it must register with CDPHE as a recycler.

EPR registration procedure in United States of America - Colorado

For EEE in Colorado, the “registration” workstream usually means recycler compliance:

1. Determine whether your operations meet CDPHE’s definition of an electronics recycling facility (e.g., dismantling, sorting, baling waste electronics).

2. Register with CDPHE using the state’s solid waste recycling facility registration process (via CDPHE’s recycling forms/applications).

3. Ensure you also comply with hazardous waste requirements if you receive business electronics that are regulated as hazardous waste.

4. Set up internal tracking so you can file the required annual recycler report (see “Reporting” and “Reporting Deadline”).

Authorized representative

Colorado’s EEE rules do not use an “authorized representative” model for producers. Responsibility is assigned directly by role (recycler, waste hauler, landfill/transfer station operator, county, state agency). Businesses commonly appoint an internal compliance owner, but that is operational—rather than a statutory “authorized representative” requirement.

Reporting

Key reporting expectations in Colorado’s EEE system include:

• Registered electronics recyclers must submit an annual report documenting the electronic materials collected in the prior year.

• Recyclers handling business electronics must follow applicable hazardous waste requirements in addition to solid waste rules.

• Counties relying on an exemption from the landfill ban should document “good-faith efforts” to secure electronics recycling services and the basis for the exemption decision.

Reporting Deadline

• Electronics recycler annual report: due by March 1 each year for the prior year’s collected material.

• Landfill ban: in effect statewide; counties can adopt an exemption for residents only under specified conditions (see below).

Who Assumes Responsibility

Colorado assigns responsibility by function:

• Consumers / businesses: must ensure electronics are managed through appropriate recycling or lawful hazardous-waste channels (not landfilled).

• Counties: must provide (or help enable) access to electronics recycling; counties lacking sufficient access may vote for a time-limited exemption for residents under statutory conditions.

• Waste haulers / landfills / transfer stations: must not accept electronic devices, and can rely on a “good-faith effort” safe harbor by posting required signage stating electronic devices will not be accepted.

• State agencies: must recycle their electronic devices and must use recyclers certified to recognized standards (e.g., R2 or e-Stewards, or comparable).

• Recyclers: must register with CDPHE (and report annually), and provide certification documentation to state agencies when accepting their devices.

Duties of Each Group

• Recyclers (EEE recyclers)

  • Register as a recycler with CDPHE if performing electronics recycling activities.

  • Submit the annual recycler report by the deadline.

  • Comply with hazardous-waste rules when receiving regulated business electronics.

  • For state-agency devices: maintain and provide documentation of required third-party certification (R2/e-Stewards or comparable).

• Waste haulers / landfills / transfer stations

  • Implement controls to prevent acceptance of electronic devices.

  • Post and maintain clear signage stating electronic devices are not accepted (supports the statutory “good-faith effort” protection).

• Counties (boards of county commissioners)

  • Make good-faith efforts to secure electronics recycling services for residents.

  • Only if access criteria are not met, may vote to exempt residents from the landfill ban for a limited period; exemption must be revisited on the statutory cycle.

• State agencies

  • Recycle electronic devices (not dispose of them).

  • Use certified recyclers and keep certification documentation in procurement/disposition workflows.

• Colorado Department of Public Health and Environment (CDPHE) / Solid & Hazardous Waste Commission

  • Administer and enforce applicable solid and hazardous waste requirements.

  • Maintain recycler registration/reporting processes and related guidance.

Who Is Responsible

If you sell electronics into Colorado, you generally don’t have an electronics “producer registration” obligation (unlike many packaging EPR programs). The parties with direct compliance duties are recyclers (registration + reporting), state agencies (certified recycling), counties (service access/exemption governance), and waste management operators (non-acceptance/signage). This distinction is important if you are building a multi-state compliance program spanning EPR registration United States of America requirements across product categories.

Additional Information for Consideration

• Landfill ban timing & county exemptions: The landfill disposal ban for electronic devices has applied since July 1, 2013. Counties may exempt residents only if they lack sufficient recycling access and follow the statute’s conditions; exemptions are time-limited and must be reconsidered on the statutory schedule.

• State-agency certification standard: Colorado requires state agencies to use recyclers certified to recognized national standards (e.g., R2 or e-Stewards or comparable). If you provide recycling services to state agencies, be ready to supply certification documentation.

• Business electronics can be hazardous waste: Colorado guidance emphasizes that many electronics from non-residential sources can be regulated as hazardous waste—this can affect storage, transport, and downstream vendor qualification.

• Don’t confuse EEE with Colorado packaging EPR: Colorado’s producer-funded recycling program under HB 22-1355 is for packaging/paper/covered materials (i.e., EPR packaging United States of America in Colorado) and is separate from the electronics landfill-ban framework.

Maine runs an EEE (electrical and electronic equipment) EPR system under its Electronic Waste law (38 M.R.S. §1610). The program is administered by the Maine Department of Environmental Protection (Maine DEP) EPR team and is designed so manufacturers fund the handling, transportation, and recycling of household-generated “covered electronic devices” (CEDs) through approved consolidators and certified downstream recyclers.

Who must register for EPR in Maine State

In Maine, the parties with direct compliance obligations include:

• Manufacturers (as defined by Maine law, including certain importers and brand owners) that offer or have offered CEDs for sale in or into Maine.

• Retailers (including online sellers) because Maine has a sales prohibition: retailers may not sell CEDs in Maine unless the manufacturer/brand is in compliance and properly registered.

• Consolidators operating consolidation facilities in Maine’s program (approval + annual operational/reporting duties).

What the package includes

For Maine EEE EPR, the scope is Covered Electronic Devices (CEDs) (not packaging). Maine’s statutory definition includes items such as:

• Desktop printers

• Video game consoles

• Cathode ray tubes/devices (CRT)

• Flat panel displays and similar video display devices with a screen greater than 4 inches diagonally and one or more circuit boards
  Maine DEP guidance also lists common examples typically treated as covered in practice (e.g., TVs, monitors, laptops, tablets, e-readers, portable DVD players, digital picture frames, certain printers, etc.).

Threshold

Maine’s program is not a “small producer threshold” model in the way some packaging EPR laws are. If you meet the legal definition of a manufacturer and sell covered products in/into Maine, you generally must comply.
There is, however, a de minimis market-share concept used for cost allocation: Maine DEP may treat a manufacturer’s market share as de minimis if it is less than 0.1% (1/10 of 1%) for a covered device category, affecting whether that manufacturer pays a pro rata share for that billing year.

EPR registration procedure in Maine State

A practical EEE EPR Maine compliance flow for manufacturers is:

1. Confirm scope: verify your products meet Maine’s CED definition (screen size + circuit board criteria, etc.).

2. Confirm manufacturer status: note that “manufacturer” can include (a) brand owners/licensors and (b) importers of devices made by entities without a U.S. presence.

3. Register with Maine DEP: manufacturers must register before offering a CED for sale in Maine and renew registration annually by the statutory deadline.

4. Maintain brand/device listing: keep your registered brands and device types accurate so retailers can lawfully sell your products in Maine.

5. Prepare for financing: consolidators invoice manufacturers for allowable handling/transport/recycling costs; manufacturers reimburse within the required timeframe.

Authorized representative

Maine’s electronics EPR does not operate on a formal “authorized representative” requirement. Instead, it assigns responsibility via the manufacturer definition, which can capture:

• An entity that imports a covered device into the U.S. when the actual manufacturer has no U.S. presence, and

• A party that owns and licenses a brand used on covered devices.
  Operationally, manufacturers often appoint a compliance contact or a third party to manage Maine DEP registration and consolidator billing, but that’s a practical choice rather than a separate legal role.

Reporting

Key reporting and record-related duties in Maine’s EEE program include:

• Manufacturer registration contents (submitted to Maine DEP) include contact/billing information plus brand names and the covered device types each brand uses (and other specified information).

• Consolidator annual accounting: consolidators must track covered devices handled and submit required accountings to Maine DEP annually.

• Downstream certification: recycling/dismantling facilities provide sworn certifications that their processing meets Maine’s environmentally sound management guidelines; consolidators must maintain these certifications and provide them to Maine DEP upon request.

Deadline

Key statutory timing points for EPR electronics Maine:

• Manufacturer label requirement: effective January 1, 2005 (covered devices sold in Maine must have a visible, permanent manufacturer label).

• Sales prohibition: effective January 1, 2006 (manufacturers/retailers cannot sell covered devices in Maine unless the manufacturer is in compliance).

• Manufacturer registration deadline: by April 1 each year (and prior to offering a covered device for sale).

• DEP market share listing: Maine DEP provides manufacturers/consolidators the market share responsibility listing by January 1 each year for the subsequent calendar year.

• Consolidator reporting: required annual accountings are due by March 1.

• Manufacturer payment timing: manufacturers reimburse consolidator invoices within 90 days of receipt (for allowable costs).

Who Assumes Responsibility

Responsibility is shared by role:

• Manufacturers fund covered device recycling costs through the consolidator billing system and must register/maintain compliance to keep products legally sellable in Maine.

• Retailers must not sell covered devices from noncompliant/unregistered manufacturers and must ensure devices meet labeling requirements.

• Municipalities (that choose to participate) ensure covered devices from covered entities in their jurisdiction are delivered to an in-state consolidation facility (often via local collection sites/events).

• Covered entities (households, qualifying small businesses/nonprofits, and schools) bring covered e-waste to collection sites/events (and may face quantity limits per drop-off event/site).

Duties of Each Group

• Manufacturers

  • Register annually with Maine DEP and keep brand/device coverage accurate.

  • Pay allowable handling/transport/recycling costs (via consolidator invoices).

  • Support retailer compliance (so products remain legal to sell in Maine).

• Retailers

  • Verify the manufacturer/brand is registered and in compliance before selling covered devices in/into Maine.

  • Ensure devices have the required manufacturer labeling.

• Consolidators

  • Operate approved consolidation facilities; track covered devices handled.

  • Invoice manufacturers according to cost allocation rules and submit annual accountings to Maine DEP.

  • Ship only to recycling/dismantling facilities that provide required certifications; retain certifications for inspection.

• Recycling & dismantling facilities

  • Provide sworn certification that processing meets Maine’s environmentally sound management guidelines.

• Municipalities / collection sites

  • Provide collection access for covered entities (when participating) and ensure devices are routed to consolidation facilities.

• Maine DEP

  • Administers registration, approves consolidators, determines market share responsibilities, and enforces the sales prohibition framework.

Who Is Responsible

If you sell electronics into Maine, you are responsible for Maine EEE obligations when you qualify as a “manufacturer” under Maine law (including certain importers and brand licensors). If you are a retailer, you are responsible for ensuring you only sell covered devices from compliant/registered manufacturers and that labeling rules are met. If you operate as a consolidator, you are responsible for approvals, accounting/reporting, invoicing, and downstream certification controls.

Additional Information for Consideration

• Drop-off quantity limit: covered entities may generally deliver no more than 7 covered electronic devices at one time to a municipal collection site or consolidator collection event unless the site/event agrees to accept more—plan consumer-facing instructions accordingly.

• Cost allocation mechanics: Maine uses a market-share-based cost allocation model across device categories; this means your Maine EEE cost exposure depends heavily on device category and your DEP-determined market share for that category.

• Market access risk: the sales prohibition is a practical enforcement lever—if you’re not registered/in compliance, retailers (including online channels) are not supposed to sell your covered devices in/into Maine.

• “Covered entity” scope: Maine’s program is built around household-type generators (households, qualifying small nonprofits/businesses, and schools). If you manage larger commercial/industrial electronics, you may need separate vendor programs outside the household EPR stream.

Maryland’s EEE (Electrical and Electronic Equipment) EPR operates under the Statewide Electronics Recycling Program (“Maryland eCycling”). It focuses on Covered Electronic Devices (CEDs) and uses a manufacturer registration + fee model (with an option for reduced fees when manufacturers provide a free, approved takeback program). Oversight sits with the Maryland Department of the Environment (MDE) EPR. For multi-state compliance, this is a practical example of EPR United States of America in the electronics category (i.e., EPR electronics United States of America) supporting United States of America electronics recycling.

Who must register for EPR in United States of America in Maryland

Registration obligations primarily apply to covered electronic device manufacturers that sell or offer for sale new CEDs in Maryland (including sales via the internet/catalogs). “Manufacturer” generally means the brand owner of a covered device brand sold/offered in Maryland.
Retailers also have a market-access obligation: retailers may only sell new CEDs from manufacturers registered with MDE.

• Ready to make extended producer responsibility effortless for USA? Request a personalized EPR fee quote now and start turning regulatory obligations into sustainable value for your brand for cross-border sales!

What the package includes

For Maryland EEE EPR, the scope is Covered Electronic Devices (CEDs), defined broadly as:

• A computer or video display device with a screen greater than 4 inches measured diagonally.

In practice, MDE’s registration guidance indicates this can include items such as computers, monitors, televisions, portable DVD players, cell phones, tablets, etc., when they meet the legal definition.
Key exclusions referenced in MDE guidance include video display devices that are part of a motor vehicle or contained within a household appliance or within commercial, industrial, or medical equipment.

Threshold

Maryland’s obligations are best viewed in two “thresholds”:

• Obligation threshold (who must register): If you sell/offer new CEDs in Maryland and qualify as a “manufacturer” under the program, you must register annually to legally sell those devices in the state.

• Fee thresholds (how much you pay): The annual registration fee is based on how many CEDs you sold in Maryland in the prior year, with reduced fees available if you have an MDE-approved takeback program:

• 0–99 CEDs sold in Maryland in the prior year: $0 registration fee

• 100–999 CEDs sold in Maryland in the prior year: $5,000 (initial; and generally also the renewal fee if no approved takeback program)

• 1,000+ CEDs sold in Maryland in the prior year: $10,000 initial registration fee (renewals are generally $5,000 if no approved takeback program)

• $500 renewal fee for manufacturers with 100+ CEDs sold in the prior year and an MDE-approved takeback program (reduced-fee pathway)

EPR registration procedure in United States of America
A practical EPR registration United States of America workflow for Maryland EEE looks like this:

• Confirm scope: Determine whether your products sold into Maryland meet the CED definition (screen > 4 inches; computer/video display device).

• Confirm “manufacturer” status: Typically the brand owner for the CED brand offered for sale in Maryland.

• Prepare your registration filing (annual): Provide company and contact details, brand names, CED types sold (desktop/laptop/video display), and the number of CEDs sold in Maryland in the prior year.

• Decide takeback strategy:

  • If you want the reduced renewal fee, establish/maintain an MDE-approved free takeback program and include required program details in your submission (toll-free number and/or website plus required consumer instructions).

• Submit registration + fee by the deadline (see “Deadline”).

• MDE review: MDE reviews for completeness, verifies the fee and sales quantities, and validates any proposed takeback program requirements.

• Maintain market access: Once registered, you are included on MDE’s public list of registered manufacturers, which retailers rely on to confirm lawful sales.

Authorized representative

Maryland does not use an EU-style “authorized representative” requirement for electronics producers. However, MDE registration materials include a field for a resident agent/authorized agent in the U.S. (if applicable)—commonly relevant where the registering entity is outside the U.S. or needs a designated in-country contact.

Reporting

Maryland’s program reporting is tied to the annual registration, with additional reporting content when a takeback program is used:

• Annual registration includes the total number of CEDs sold in Maryland in the prior year, including the types of devices and the brand names under which they were sold.

• If you operate a takeback program, you must provide program contact information (toll-free number/website) and, after at least one year of operation, provide an annual update/report describing the program’s prior-year performance (including weight received from Maryland, number of devices handled, and recycling/refurbishment/reuse methods).

• MDE notes that manufacturers must also provide educational materials on data destruction and device sanitization as part of the takeback expectations and program guidance.

Deadline

Key timing points for Maryland EEE EPR:

• Annual manufacturer registration and fee due: by March 1 each year.

• Registration validity window: MDE’s published manufacturer list is organized as March 1 through February 28 (i.e., a March–February program year).

• Device requirements for lawful sale: A manufacturer may not sell/offer new CEDs in Maryland unless the device is labeled with the manufacturer name or brand label and the manufacturer is registered (and fee paid if applicable).

• Retailer sales restriction: Retailers may not sell new CEDs from manufacturers that are not properly registered with MDE.

Who Assumes Responsibility? Duties of Each Group Who Is Responsible

Manufacturers (primary responsible party)

• Register annually with Maryland Department of the Environment (MDE) EPR by the deadline.

• Label covered devices with the manufacturer name or brand label.

• Pay the applicable registration fee based on prior-year Maryland sales.

• If using the reduced-fee pathway, operate an MDE-approved free takeback program and provide required consumer information (and annual takeback performance updates as required).

Retailers (market access gatekeeper)

• Sell new CEDs only from manufacturers registered with MDE (verify via MDE’s registered manufacturer list).

Consumers / end users

• Use manufacturer takeback programs (where provided) and/or county/retail collection options publicized by MDE for compliant recycling.

Maryland Department of the Environment (MDE)

• Receives and reviews registrations and fees, maintains the public list of registered manufacturers, and can identify insufficiencies requiring correction.

Quick rule (who is responsible): If you are the brand owner offering new covered computers/video display devices (>4” screen) into Maryland, you are typically the “manufacturer” and must register to keep your products legally sellable in the state; retailers must verify that registration before selling.

Additional Information for Consideration

• Reduced-fee takeback program requirements are specific: MDE describes an approved takeback program as free, including a no-cost method for consumers to return a CED (e.g., free shipping and shipping container, or convenient drop-off locations), plus providing data wiping instructions or links to free data-wiping tools.

• Confidentiality note: Maryland treats submitted manufacturer sales data as confidential/proprietary under the statute.

• Processing time and planning: MDE guidance indicates a typical manufacturer registration turnaround time of up to 60 days and a registration term of up to 12 months—build this into launch calendars and retailer onboarding.

• Watch for legislative changes: Bills were introduced in 2025 (HB 931 / SB 591) proposing a major modernization of Maryland’s electronics program; monitor future sessions if you need early warning on program redesign.

Minnesota’s EEE framework is commonly referred to as the Minnesota Electronics Recycling Act and is codified in Minnesota Statutes §§ 115A.1310–115A.1330. It functions as an EPR United States of America model for household electronics: manufacturers of “video display devices” (VDDs) must register and meet a recycling obligation, and the system is overseen by the Minnesota Pollution Control Agency (MPCA) EPR, with fees administered through the Minnesota Department of Revenue. pca.state.mn.us+3revisor.mn.gov+3revisor.mn.gov+3

Who must register for EPR in United States of America Minnesota State

Manufacturers: a “manufacturer” is generally the brand owner selling VDDs under its own brand label (including selling devices manufactured by others under its own brand). Manufacturers must file a registration with the MPCA to sell/offer new VDDs to Minnesota households
Retailers (sales restriction, not “registration”): retailers must not sell/offer/rent/lease a VDD unless it is labeled and the manufacturer/brand is listed as registered on the MPCA website. 
Collectors and recyclers: to operate as a collector (receiving household covered devices and arranging delivery to a recycler) or to recycle household-generated VDDs, an entity must submit a registration to the MPCA by the statutory deadlines.

What the package includes

Minnesota’s EPR electronics scope is built around two key definitions:

• Covered electronic device (CED): computers (including tablets and laptops), peripherals, facsimile machines, DVD players, video cassette recorders, and video display devices sold to a household via retail/wholesale/e-commerce.

• Video display device (VDD): a television or computer monitor containing a CRT or flat panel screen marketed for household use, with notable exclusions for motor vehicles and certain industrial/commercial/medical equipment contexts.
  In practice: manufacturers’ registration/sales gating is tied to VDDs, while pounds of household CEDs collected/recycled are used to meet obligations and generate/track credits under the program.

Threshold

Sales/fee threshold: manufacturers that sell 100 or more VDDs to Minnesota households in the previous calendar year pay a $2,500 registration fee plus a variable recycling fee; manufacturers selling fewer than 100 VDDs do not owe the $2,500 component (but statute still describes a variable fee calculation).
Obligation basis: MPCA describes the manufacturer recycling obligation as based on the manufacturer’s market share of VDD sold in Minnesota. 
Program year: July 1 through June 30.

EPR registration procedure in United States of America in Minnesota

Manufacturer (VDD) registration and compliance steps for EPR registration United States of America (Minnesota):

1. Confirm you are a “manufacturer” and your products are “video display devices” sold/offered to Minnesota households.

2. Register with MPCA by the annual deadline; include your brands offered for sale in Minnesota, a compliance contact, and a certification of compliance

3. If you begin selling after the deadline, file registration within 10 days; update registration within 10 days after brand changes.

4. Complete required annual reporting through MPCA’s system (Re-TRAC Connect is used per MPCA guidance).

5. File/pay the Minnesota e-waste registration fee return to the Minnesota Department of Revenue (working with MPCA).

Authorized representative

Minnesota does not use an “authorized representative” concept like some EU regimes. Instead, manufacturer registration must identify a person responsible for ensuring compliance (a designated compliance contact). revisor.mn.gov+1

Reporting

Manufacturers have two main annual reporting obligations:

• By March 1 each year: report the weight of each model of VDD sold to Minnesota households in the previous calendar year (and required total-weight calculation methodology).

• By August 15 each year: report the total weight of household CEDs collected/recycled (or arranged) during the preceding program year and report recycling credits activity and elections used for variable fee calculations.

• Collectors and recyclers also have annual reporting:

• Recyclers: by July 15 each year, report total CED weight recycled in the preceding program year and related program details. Collectors: by July 15 each year, report total pounds collected, recyclers used, and whether they had contracts tied to meeting manufacturers’ obligations.

Deadline

Key dates for Minnesota EEE EPR (useful for compliance calendars):

• Program year runs July 1 to June 30.

• March 1: manufacturer sales/market reporting due to MPCA.

• July 15: collector and recycler registration and reporting due to MPCA.

• August 15: manufacturer registration due/validity cycle, and manufacturer recycling/credits reporting due to MPCA.

• August 15: annual e-waste registration fee return due to Minnesota Department of Revenue.

Who Assumes Responsibility

Manufacturers must annually recycle or arrange for collection and recycling to meet the obligation determined by MPCA, and must assume financial responsibility for transporting and recycling covered devices used to meet the obligation (while certain “receiving and aggregating” costs are excluded
Manufacturer obligations apply only to VDDs received from households (not non-household sources).
Manufacturers must use registered recyclers and only materials processed by appropriately certified recyclers are eligible to meet obligations.

Duties of Each Group

Manufacturers (primary EPR party for Minnesota household electronics)

• Register annually with MPCA and keep registration updated for brand changes.

• Meet the recycling obligation and finance eligible transport/recycling costs.

• Conduct and document due diligence on collectors/recyclers and retain documentation for three years showing downstream compliance.

• Report sales/market data (March 1) and recycling/credits data (August 15).

Retailers

• Sell only VDDs that are properly labeled and whose manufacturers/brands are listed as registered by MPCA.

• Provide households information on where/how to recycle VDDs (can be satisfied via MPCA’s toll-free number/website; online sellers can provide it prominently on their website).

Collectors

• Register annually and report annually; operate collection sites consistent with statutory requirements (e.g., staffed and adequately open; may impose reasonable acceptance limits).

• Use only registered recyclers.

Recyclers

• Register annually and report annually; certify compliance with program requirements and downstream standards.

Minnesota Pollution Control Agency (MPCA) EPR and Minnesota Department of Revenue

• MPCA administers registration and reporting and maintains the registered manufacturer/brand listing.

• The Department of Revenue collects the e-waste registration fee return and works with MPCA on the program.

Who Is Responsible

If you are the brand owner selling VDDs to Minnesota households, you are typically the “manufacturer” and responsible for MPCA registration, reporting, and meeting the recycling obligation (i.e., Minnesota’s EPR electronics obligations).
If you collect or recycle household electronics in Minnesota, you are responsible for annual MPCA registration and reporting as a collector/recycler.
If you are a retailer, you are responsible for selling only registered brands and providing consumer recycling information.

Additional Information for Consideration

• Registration validity and retailer risk window: manufacturer registration is valid until August 15 each year; retailers have a limited protection window if they possessed inventory before a manufacturer registration expired/revoked and the sale occurs within six months after the expiration/revocation.

• Household focus: MPCA’s registered brand list is explicitly described as household-market focused and not a list of manufacturers “qualified” for exempt industrial/commercial markets.

• Certified recycler requirement: eligible pounds must be processed by a registered recycler certified by an ANSI-ASQ National Accreditation Board–accredited body to an environmentally sound management standard.

• CRT disposal restrictions context: Minnesota banned disposal of certain electronics containing CRTs in mixed municipal solid waste in 2006 (helpful context when explaining compliance expectations to operations teams and customers).

• This is separate from other Minnesota EPR-style programs: Minnesota also has producer responsibility programs in other product categories (e.g., batteries/other stewardship programs) that should not be confused with Minnesota’s EEE program scope.

Oregon’s electronics EPR program is called Oregon E-Cycles. It is administered by the Oregon Department of Environmental Quality (DEQ) and is designed so manufacturers fund the statewide collection, transportation, and responsible recycling of covered electronic devices. A modernized version of the program starts January 1, 2026 under HB 3220 (2023), expanding the list of covered devices and strengthening statewide convenience requirements.

Who must register for EPR in United States of America in Oregon

Manufacturers: You must register if you sell or offer for sale covered electronic devices in or into Oregon in the program year (for 2026), or if your brands were sold in Oregon in the prior year and are not being registered by another manufacturer.
Retailers: Retailers have “market access” duties (not manufacturer-style registration). They may sell only brands on Oregon’s manufacturer compliance list, must provide consumers point-of-sale information on free recycling, and must confirm covered devices are permanently and visibly brand-labeled (with limited exceptions).
Producer Responsibility Organizations (PROs): Manufacturers must designate a PRO, and PROs must submit a DEQ-approved program plan to operate.

What the package includes

For Oregon EEE EPR, the scope is electronics (not packaging).
Current Oregon E-Cycles consumer-facing scope (pre-2026) includes free recycling of: computers (desktops, laptops, tablets), monitors, TVs, printers, and limited peripherals (e.g., keyboards and mice), with a typical drop-off limit of seven items at a time.
Starting in 2026, Oregon expands “covered electronic devices” to include additional categories (examples include: fax machines, VCRs, portable digital music players, DVD/DVR devices, video game consoles, digital converter boxes, cable/satellite receivers, scanners, small-scale servers, routers/modems, and broader peripherals such as certain cords/controllers/headphones).

Threshold

Oregon’s modernized program includes an exemption for manufacturers that sell fewer than 50 covered electronic devices in a given year in Oregon.
Retail sales restrictions generally apply only to devices covered under the law, and there is a specific note that only manufacturers of keyboards and mice are excluded from the registration requirement under the retailer guidance.

EPR registration procedure in United States of America (Oregon)

1. Confirm scope: Determine whether you (or your brands) sell “covered electronic devices” in or into Oregon for the relevant program year.

2. Register online: Manufacturers must register through the Oregon E-Cycles registration portal (managed by the Electronics Recycling Coordination Clearinghouse / ERCC).

3. Provide required information: Keep company/contact details current and list all current and past brands associated with covered devices.

4. Select your PRO: During registration, confirm your intended PRO for the program year (and ensure that PRO has a DEQ-approved plan).

5. Certify compliance: Submit required certifications during registration and maintain accuracy (updates are important because retailer market access depends on the compliance list).

6. Submit sales data: Manufacturers must submit required market/sales data annually so DEQ can calculate market share (which is used to set manufacturer obligations/fee allocation).

Authorized representative

Oregon’s electronics EPR does not rely on an EU-style “authorized representative” requirement. Compliance responsibility is assigned to the manufacturer and implemented through the manufacturer’s chosen PRO (and, if multiple PROs are approved, a coordinating body may be designated). Practically, manufacturers typically appoint an internal compliance owner (or a compliance service provider) to manage registration, sales data submission, and PRO coordination.

Reporting

Manufacturers: Submit annual sales/market data to DEQ (used to calculate market share).
PROs: Operate under a DEQ-approved plan and meet plan obligations (collection network, public awareness/education, equitable statewide service, and other requirements in statute/rule). PRO annual reporting begins on the program timeline (for example, annual reports for the 2026 program year are due in 2027 under the published timeline).

Deadline

For the 2026 program year (modernized E-Cycles):

• Registration window: Oct. 15 – Dec. 31, 2025.

• Manufacturer registration deadline to legally sell covered devices in Oregon in 2026: Dec. 31, 2025.

• Program launch: Jan. 1, 2026.

• Manufacturer submission of 2025 sales data to DEQ: Jan. – March 2026 (per DEQ timeline).

• DEQ market share calculation and review cycle: April – May 2026 (per DEQ timeline).

• PRO annual fee to DEQ for the program year: June 1 (per DEQ timeline).

• For future years, the timeline shows a similar cycle (PRO plan due July 1; manufacturer registration in Oct–Dec; sales data submission Jan–Mar).

Who Assumes Responsibility

Manufacturers assume financial responsibility by funding Oregon E-Cycles through their chosen PRO (and by completing manufacturer registration and sales data reporting that drives market share and obligation allocation).
PROs (and any designated coordinating body) assume operational responsibility for running the statewide collection/recycling system under the DEQ-approved plan (including convenience and public awareness requirements).
Retailers assume responsibility for ensuring only compliant brands are sold (via the compliance list), providing point-of-sale recycling information, and confirming device labeling.

Duties of Each Group

Manufacturers

• Register annually and designate a PRO with a DEQ-approved plan for the program year.

• Submit required sales/market data annually.

• Fund the program through PRO fees based on market share/obligation allocation.

• Maintain accurate company/brand information so retailers can verify compliance.

Retailers

• Provide point-of-sale information about free recycling options.

• Sell only brands listed on Oregon’s manufacturer compliance list (for covered devices).

• Confirm covered devices are permanently and visibly brand-labeled (with limited exceptions noted in guidance).

PROs (and coordinating body, if applicable)

• Submit program plans for DEQ approval on the statutory schedule.

• Operate a compliant statewide collection network and meet service, convenience, and education/awareness expectations.

Oregon DEQ (environmental authority)

• Maintains the program framework, reviews/approves plans, administers manufacturer registration and sales data processes, calculates market share, and provides guidance and public resources (including collection site search tools and compliance information).

Who Is Responsible

If you are the brand owner/manufacturer selling covered electronic devices into Oregon, you are responsible for manufacturer registration, selecting a compliant PRO, submitting annual sales data, and funding obligations through the program.
If you are a retailer, you are responsible for selling only compliant brands for covered devices and providing consumer-facing recycling information at point of sale.

Additional Information for Consideration

• Landfill ban context: Oregon’s program has long been tied to keeping certain covered devices (notably TVs/monitors/computers) out of landfills; the modernization does not change that landfill-ban concept, but it expands what devices the program accepts and strengthens collection network requirements.

• Consumer drop-off limit: Oregon’s public-facing guidance emphasizes “seven or fewer” devices at a time for free recycling at participating sites; heavier items (e.g., console TVs) may require calling ahead.

• 2026 expansion impact: If you previously scoped only “computers/monitors/TVs/printers,” you may become newly obligated in 2026 because additional device categories are added to the covered definition.

Washington’s electronics EPR program is E-Cycle Washington. It is administered by the Washington State Department of Ecology and requires manufacturers to finance the collection, transportation, and recycling system for covered electronics through participation in an approved plan (typically the Standard Plan operated by the Washington Materials Management & Financing Authority, WMMFA).

Who must register for EPR in United States of America in Washington State

Manufacturers: If you are a “manufacturer” of a covered electronic product sold in or into Washington (including brand owners, assemblers, private-label retailers, and certain importers), you must register annually with Ecology, pay the annual administrative fee, and participate in an approved plan to legally sell in Washington.
Collectors: Businesses that collect covered electronic products for a plan (and want to be compensated under the program) must register annually, meet performance standards, and be listed as “in compliance.”
Transporters: Businesses transporting covered electronic products for a plan (and wanting compensation under the program) must register annually, meet performance standards, and be listed as “in compliance.”
Direct processors: Facilities that dismantle/shred/process covered electronic products for a plan must register (and renew annually), meet performance standards, and comply with annual audit requirements.
Retailers / remote sellers: While retailers don’t register as “manufacturers,” they have market-access and point-of-sale information duties, including checking Ecology’s registration lists and providing required consumer recycling information.

Ready to make extended producer responsibility effortless for USA? Request a personalized EPR fee quote now and start turning regulatory obligations into sustainable value for your brand for cross-border sales!

What the package includes

This is EEE-only (not packaging). Washington’s legal minimum scope for “covered electronic products” includes:

• Computer monitors (CRT or flat panel) with a viewable area greater than 4 inches

• Desktop computers

• Laptop or portable computers

• Televisions (CRT or flat panel) with a viewable area greater than 4 inches
  (With statutory exclusions for certain embedded equipment, vehicles/aircraft-integrated units, medical devices, certain monitoring/control instruments, and handheld portable voice/data devices used for commercial mobile services.)

In addition, Washington’s public-facing E-Cycle Washington program accepts for free (from eligible participants) items such as tablets, e-readers, and portable DVD players, depending on program guidance and collection site acceptance rules.

Threshold

There is no general de minimis “small producer” exemption in the core Washington E-Cycle manufacturer-registration requirement: if you sell covered electronic products in or into Washington, you are generally in scope.
On the end-user side, “covered entities” eligible for the program include households, charities, school districts, small businesses (fewer than 50 employees), and small governments (as defined in law/program guidance).

EPR registration procedure in United States of America (Washington)

1. Confirm whether you qualify as the “manufacturer” under Washington’s definitions (brand owner/private label/importer scenarios matter).

2. Create a SecureAccess Washington (SAW) account and add the “Electronic Product Recycling Registration” service.

3. Submit the annual manufacturer registration to Ecology (including required company and brand information).

4. Pay the annual administrative fee (separate from any plan/PRO fees you may owe under the Standard Plan or an Independent Plan).

5. Ensure you are participating in an approved plan:

   • Standard Plan: participation is automatic unless you qualify and choose to operate an approved Independent Plan.

   • Independent Plan: submit and operate an Ecology-approved plan (or join a group plan) if you meet the criteria to opt out of the Standard Plan.

6. Maintain compliant product labeling: covered electronic products sold/offered for sale in or into Washington must be permanently and visibly labeled with the manufacturer’s brand.

7. If you act as (or hire) collectors/transporters/processors for a plan, ensure they are properly registered and in “in compliance” status on Ecology’s lists.

Authorized representative

Washington’s EEE EPR framework does not use an EU-style “authorized representative” concept. Compliance responsibility sits with the manufacturer and its selected plan structure (Standard Plan via WMMFA or an approved Independent Plan). In practice, manufacturers should designate a responsible compliance contact to manage Ecology registration, fee payment, brand maintenance, and plan coordination.

Reporting

Manufacturers: Washington uses market share (by weight) to allocate responsibility; Ecology may rely on market research and on sales data supplied by manufacturers and/or retailers to determine market share.
Plans (authority/authorized parties): The authority (WMMFA Standard Plan) and any authorized party operating an Independent Plan must file annual reports for the preceding program year that include collection and recycling results (including weights by product type and county), collection-site/service details, and processor information.
Collectors / transporters / processors: Must meet ongoing registration, performance standards, and (for processors) annual audit requirements; their compliance status is reflected on Ecology’s registration lists.

Deadline

Manufacturer registration and the annual administrative fee are due annually by January 1.
Annual plan reporting (authority/authorized parties) is due by March 1 each year for the preceding program year (after the program’s initial phase specified in law).
Collectors and transporters have an annual renewal window generally between June 1 and September 1 to remain eligible for plan work in the next program year (new entities may be able to register outside the renewal window, subject to program rules).
Direct processors must register/renew annually; new processors must register at least 30 days before receiving covered electronic products for processing and cannot begin until Ecology determines they meet performance standards and they appear on the registered list.

 Duties of Each Group Who Is Responsible

• Manufacturers assume financial and compliance responsibility: annual registration, administrative fee payment, plan participation, and ensuring their products can be legally sold in Washington.

• Plans (Standard Plan authority and Independent Plan authorized parties) assume operational responsibility for running collection/recycling services statewide and meeting plan performance and reporting obligations.

• Retailers/remote sellers assume responsibility for selling compliant products (brand-labeled, registered manufacturers) and providing required consumer recycling information.

• Registered collectors, transporters, and direct processors assume responsibility for meeting program performance standards and maintaining compliant registration status.

Manufacturers

• Register annually; keep brand lists current; pay the annual administrative fee.

• Participate in an approved plan (Standard Plan by default, or approved Independent Plan if eligible).

• Ensure covered products are permanently and visibly brand-labeled.

Retailers / remote sellers

• Check Ecology’s manufacturer registration/plan lists and only sell covered products from compliant manufacturers.

• Provide required point-of-sale / online information to consumers about how to recycle covered electronics.

Plans (Standard Plan authority / Independent Plan authorized party)

• Provide collection services meeting statutory convenience requirements and serve covered entities.

• Use registered, compliant collectors/transporters/processors.

• File annual reports and meet any equivalent-share/market-share performance obligations.

Collectors / transporters

• Register annually; meet WAC performance standards; remain listed as “in compliance.”

Direct processors

• Register/renew annually; meet processor performance standards; complete annual audits; update registration details within required timeframes.

Who is responsible

If you are the brand owner (or otherwise meet Washington’s “manufacturer” definition) for covered electronic products sold in or into Washington, you are the responsible party for manufacturer registration, fees, and plan participation. Retailers are responsible for market-access checks and required consumer information. Operational recycling obligations are carried out through the Standard Plan (WMMFA) or an approved Independent Plan, funded by manufacturers.

Additional Information for Consideration

• Program year alignment: Washington defines the “program year” as a full calendar year. This matters for plan reporting and performance tracking.

• Market access is real: Washington law restricts sales of covered products unless the manufacturer is registered and participating in an approved plan, and products must be properly brand-labeled.

• Fees split into “state admin” vs “plan operations”: Ecology’s annual administrative fee is separate from any plan fees charged to fund actual collection/recycling operations.

• Compliance dependencies: If your plan uses collectors/transporters/processors, their “in compliance” status on Ecology’s registration lists can directly affect your ability to operate smoothly.

California has two main battery-related “EPR-style” compliance tracks managed under CalRecycle EPR programs:

1. The Responsible Battery Recycling Act (AB 2440, 2022) (“Battery Stewardship”) — a producer-funded stewardship program for covered batteries (loose primary and rechargeable batteries that are easy to remove).

2. SB 1215 (2022) — a point-of-sale recycling fee for covered battery-embedded products (CBEPs) under California’s Covered Electronic Waste (CEW) system, with collection and remittance handled through the state fee system.

Who must register for EPR in United States of America in California

Battery Stewardship (AB 2440 – covered batteries)

• Producers of covered batteries are the obligated parties (generally the brand/trademark owner; if none is in-state, responsibility steps down to the exclusive licensee, and then to the seller/importer/distributor in California).

• Producers typically comply by operating individually or joining a stewardship organization / “program operator” that runs the program on behalf of multiple producers.

• CalRecycle maintains and publishes a list of covered battery producers and brands for program transparency/verification.

Battery-embedded products fee (SB 1215 – CBEPs)

• Retailers (and in certain cases vendors/feepayers under California’s fee procedures) must collect the covered battery-embedded (CBE) waste recycling fee at the point of sale/lease of a new or refurbished covered battery-embedded product sold for use in California and remit it through the state fee system.

• Manufacturers of CBEPs have product-listing/notification, labeling, and later annual reporting duties (separate from the retailer collection/remittance duty).

What the package includes

Battery Stewardship (AB 2440 – “covered batteries”)
Covered batteries include loose primary and rechargeable batteries that are:

• sold separately, or individually packed with a product, and

• designed to be easily removed from a product using no more than common household tools.
  California also lists key exclusions from “covered batteries,” including certain large batteries by weight/energy, lead-acid batteries, motor vehicle batteries, certain fuel cell electrical generating facilities, certain medical-device batteries, recalled batteries, and other excluded categories.

Battery-embedded products fee (SB 1215 – “covered battery-embedded products”)
Covered battery-embedded products are products containing a battery that is not designed to be easily removed by the user with no more than commonly used household tools. California’s CBEP scope excludes certain categories such as specified medical devices, certain energy storage systems, and electronic nicotine delivery systems (and it is structured so it does not simply duplicate the older CEW “video display device” scope).

Threshold

Battery Stewardship (AB 2440 – covered batteries)

• California’s Battery Stewardship program is structured as a broad producer responsibility system for covered batteries; it is not framed as a simple “small producer threshold” exemption on the public program overview. In practice, the key scoping step is whether your batteries meet the “covered battery” definition (and are not excluded).

Battery-embedded products fee (SB 1215 – CBEPs)

• If you sell or lease new or refurbished CBEPs for use in California, the fee is generally in scope. The practical “threshold” is product classification: whether the item is a CBEP and not excluded.

EPR registration procedure in United States of America California

Battery Stewardship (AB 2440 – covered batteries)

1. Confirm whether your batteries are “covered batteries” and whether any exclusions apply.

2. Determine who is the legally responsible “producer” (brand owner → licensee → seller/importer/distributor hierarchy).

3. Decide compliance route: participate in a stewardship organization (program operator) or run an individual program operator approach (if feasible).

4. Prepare for the stewardship plan process: program operators must submit a stewardship plan to CalRecycle on the statutory timeline that is tied to when final regulations become effective (see “Deadline”).

5. Ensure your brands appear correctly on CalRecycle’s covered battery producer/brand listings and maintain compliance documentation/recordkeeping for CalRecycle oversight.

Battery-embedded products fee (SB 1215 – CBEPs)

1. Confirm whether your products are CBEPs and whether any exclusions apply.

2. Manufacturers: build the annual process to identify covered vs exempt models and communicate that list to California retailers and CalRecycle (by the statutory date).

3. Retailers: register/prepare in the CDTFA system (as applicable), configure checkout to collect the CBE fee and show it correctly, and remit through the state process.

4. Manufacturers: ensure labeling is compliant beginning 2026 (manufacturer/brand label; battery chemistry labeling or website disclosure).

5. Manufacturers: prepare for CalRecycle annual manufacturer reporting that begins later in the statutory rollout.

Authorized representative

Battery Stewardship (AB 2440)

• California does not use an EU-style “authorized representative” requirement for batteries. Instead, it uses a “producer” definition plus a program operator concept where producers can comply individually or via a stewardship organization.

Battery-embedded products fee (SB 1215)

• California likewise does not rely on an EU-style authorized representative concept here; obligations are assigned directly to manufacturers (notice/labeling/reporting) and retailers (fee collection/remittance).

Reporting

Battery Stewardship (AB 2440 – covered batteries)

• Program operators will be expected to submit stewardship plans and later annual reports, and CalRecycle can evaluate annual reports and maintain compliance listings.

• Recordkeeping obligations apply to regulated entities in the battery stewardship framework, and CalRecycle/DTSC can request records to evaluate compliance.

Battery-embedded products fee (SB 1215 – CBEPs)

• Manufacturers must provide annual notices identifying covered vs exempt products (with brand/model detail).

• Manufacturers must begin sending CalRecycle annual manufacturer reports on the statutory date.

• Retailers/feepayers must file and remit the fee through CDTFA’s fee administration process.

Deadline

Battery Stewardship (AB 2440 – covered batteries)

• California’s public Battery Stewardship timeline is relative to the effective date of final regulations:

  • Regulations: CalRecycle’s public timeline states regulations take effect no earlier than April 1, 2025 (actual effective date depends on final adoption).

  • 120 days after regulations are effective: CalRecycle appoints an advisory body.

  • 12 months after regulations are effective: program operators submit a stewardship plan to CalRecycle.

  • 24 months after regulations are effective: program operators must have an approved stewardship plan.

  • 12 months after plan approval: program operators must fully implement the approved plan.

• Separately, California indicates AB 2440 repeals and replaces older rechargeable battery / cell phone takeback statutes on future effective dates (important for transition planning).

Battery-embedded products fee (SB 1215 – CBEPs)

• By July 1, 2025: manufacturers must send the annual notice listing covered and exempt CBEPs to retailers and CalRecycle.

• January 1, 2026: retailers must begin charging the CBE waste recycling fee at sale/lease; CalRecycle has established the initial fee rate at 1.5% of retail sales price, capped at $15 per product.

• April 1, 2026: CalRecycle begins accepting payment claims for covered battery-embedded waste collected on or after January 1, 2026.

• July 1, 2027: manufacturers must begin sending CalRecycle annual manufacturer reports for CBEPs.

• Ongoing: CalRecycle may adjust the CBE fee (statutory authority beginning August 1, 2026) and may later create multiple fee categories (beginning August 1, 2028), if necessary.

Who Assumes Responsibility

Battery Stewardship (AB 2440)

• Producers assume responsibility for end-of-life management of covered batteries, typically by funding and operating (directly or through a stewardship organization) a statewide stewardship program.

Battery-embedded products fee (SB 1215)

• Retailers (and other defined feepayers where applicable) assume responsibility for collecting/remitting the point-of-sale CBE fee.

• Manufacturers assume responsibility for the required product notice, labeling, and later annual manufacturer reporting.

Duties of Each Group

Battery Stewardship (AB 2440 – covered batteries)

• Producers / program operators

  • Establish, fund, and implement a covered battery stewardship program.

  • Submit stewardship plans and later reports consistent with CalRecycle’s regulations and timelines.

  • Provide convenient, free collection and statewide outreach/education as required by the program framework.

  • Maintain records and provide them upon request for compliance review.

• CalRecycle (local environmental authority)

  • Adopts regulations, reviews stewardship plans, posts compliant producer/brand information, evaluates reports, and enforces the battery stewardship program framework.

• DTSC

  • Oversees hazardous/universal waste management standards that apply to batteries and can intersect with collection/handling requirements.

Battery-embedded products fee (SB 1215 – CBEPs)

• Manufacturers

  • Identify covered vs exempt CBEP models and notify retailers/CalRecycle annually.

  • Ensure required labeling (manufacturer/brand and battery chemistry labeling or online disclosure) beginning in 2026.

  • Submit CalRecycle annual manufacturer reports starting in 2027.

• Retailers / lessors

  • Collect the CBE fee at point of sale/lease and remit via CDTFA procedures; maintain fee compliance in pricing/checkout.

• CalRecycle / CDTFA

  • CalRecycle sets the fee rate and administers the CBEP program framework; CDTFA administers collection/remittance under the fee procedures system.

Who Is Responsible

If you sell batteries in California, you are likely responsible under EPR battery United States of America (California) if you are the “producer” of covered batteries (AB 2440 scope) or if you place battery-embedded products on the California market (SB 1215 scope). Practically:

• Loose/easily removable batteries → producer stewardship responsibilities (AB 2440).

• Non-removable batteries embedded in products → CBEP notice/label/report duties (manufacturers) and a point-of-sale fee (retailers) (SB 1215).

Additional Information for Consideration

• Plan your compliance as “two lanes” even if you sell the same brand in both forms: AB 2440 (loose/easily removable batteries) and SB 1215 (battery-embedded products) have different mechanics (stewardship program vs point-of-sale fee).

• Expect evolving details for AB 2440 as CalRecycle finalizes permanent regulations (submission formats, stewardship plan contents, collection convenience standards, reporting templates, enforcement and penalty specifics).

• For CBEPs, the fee is a state-administered charge: ensure billing/ERP systems can (a) calculate 1.5% with a $15 cap, (b) apply to leases where required, (c) handle exemptions correctly, and (d) support audit-ready records.

• Batteries are regulated as universal waste in California, so collection/handling partners should follow DTSC universal waste battery standards (important for operational risk, fire prevention, and vendor qualification).

Colorado adopted a battery EPR framework through the Battery Stewardship Act (SB25-163). The law creates a statewide “battery stewardship program” overseen by the Colorado Department of Public Health and Environment (CDPHE), where producers finance and operate collection, transportation, processing, and recycling of covered batteries through a battery stewardship organization (BSO).

Who must register for EPR in United States of America in Colorado

Producers: Beginning August 1, 2027, any producer selling, offering for sale, or distributing covered batteries or battery-containing products in or into Colorado must participate in and finance a BSO that has submitted a stewardship plan to CDPHE, and producers may not sell/distribute unless they participate in a plan.
Battery stewardship organizations (BSOs): A BSO (producer-run or a designated nonprofit) must submit a stewardship plan and operate the program under an approved plan.
Retailers: Starting July 1, 2029, retailers may not sell covered batteries or battery-containing products unless the producer participates in a BSO with an approved plan. Retailers (and producers/BSOs) are also prohibited from charging a point-of-sale fee to consumers to cover BSO/program costs.
Special producer-allocation rules: For batteries, the “producer” is generally the battery manufacturer or brand owner (with fallback to licensee, importer of record, or first seller into Colorado if no commercial presence exists). For battery-containing products, the producer is generally the product manufacturer or brand owner (with similar fallback rules). A seller of a battery-containing product may be excluded from being the “producer” if the only batteries in/supplied with the product are supplied by a producer that has joined a BSO with an approved plan and provides written certification; producer responsibility can also be contractually assumed by another party if properly acknowledged within a BSO’s approved plan.

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What the package includes

This is battery-only (not packaging or WEEE). Colorado’s program applies to “covered batteries,” which include:

• Portable batteries

• Medium-format batteries

• Any battery sold loose or as an easily removable battery within a battery-containing product or a motorized device
  Easily removable means intended/designed to be removable by the user with no more than commonly used household tools.
  Embedded batteries (not designed to be easily removable) are excluded from “covered battery.”
  Covered battery exclusions also include (high level): certain batteries contained in medical devices, batteries with free liquid electrolyte, lead-acid batteries weighing more than 11 pounds, damaged/defective/recalled batteries, and certain vehicle-related batteries designed to power motor vehicles/parts/components.

Threshold

Colorado’s battery EPR scope is primarily definition-based (portable + medium-format + loose/easily removable). There is no general “small producer” de minimis threshold stated in the core applicability trigger; the key threshold is whether you place “covered batteries” (or products containing/packaged with covered batteries) on the Colorado market and whether exclusions apply.
Battery-size thresholds used in definitions:

• Portable batteries: primary batteries ≤ 4.4 lbs; rechargeable batteries ≤ 11 lbs and ≤ 300 Wh

• Medium-format batteries: primary batteries ≥ 4.4 lbs and ≤ 25 lbs; rechargeable batteries > 11 lbs or > 300 Wh (or both) and ≤ 25 lbs and ≤ 2,000 Wh
  Marking exception threshold: marking requirements do not apply to a covered battery that is smaller than 1/2 inch in diameter or does not contain a surface length exceeding 1/2 inch.

EPR registration procedure in United States of America in Colorado

1. Confirm scope: classify your batteries as portable/medium-format and confirm they are loose/easily removable (and not embedded or otherwise excluded).

2. Identify the legally responsible “producer”: apply the hierarchy (manufacturer/brand owner → licensee → importer → first seller into Colorado, depending on commercial presence and branding).

3. Choose compliance route: join an existing battery stewardship organization (BSO) or create/designate one (a producer can implement directly, or designate a nonprofit BSO).

4. Plan development (BSO): the BSO prepares and submits a battery stewardship plan to CDPHE on the statutory schedule (and then every 5 years).

5. Plan fees (BSO): pay the one-time plan submission fee and (if approved) the approval fee; then budget for ongoing annual administrative fees set by rule and paid to CDPHE after plan approval.

6. Producer onboarding (BSO): producers participate in and finance the BSO (beginning by the statutory “in-market” compliance date) and ensure their batteries/products remain eligible for sale.

7. Downstream readiness: align retailer communications and product data so retailers can verify compliance ahead of the 2029 retailer sales prohibition.

8. No POS fee: ensure commercial teams do not add a point-of-sale fee intended to cover BSO/program costs (explicitly prohibited).

Authorized representative

Colorado does not use an EU-style “authorized representative” model. Instead, it hard-codes a producer hierarchy that effectively assigns an obligated party even when the brand owner/manufacturer lacks U.S. or Colorado commercial presence (e.g., shifting responsibility to the importer of record or first seller into Colorado, depending on the fact pattern).

Reporting

Battery stewardship organizations must submit annual reports beginning June 1, 2029 (and each June 1 thereafter). Annual reports must cover program implementation performance for the preceding year, and approved-plan BSOs must also coordinate public awareness survey work and share results through annual reporting.
CDPHE must also submit an assessment to the Colorado General Assembly on opportunities/challenges for end-of-life battery management by March 1, 2028.

Deadline

• July 1, 2027: BSOs must submit a battery stewardship plan to CDPHE (and every 5 years thereafter).

• August 1, 2027: producers must participate in and finance a BSO that has submitted a plan; producers may not sell/distribute covered batteries or battery-containing products unless participating.

• January 1, 2028: marking/labeling requirements begin (producer identification + chemistry + “do not dispose as household waste,” with the small-battery marking exception).

• By January 1, 2029 (key operational milestone): medium-format battery collection access must be provided statewide under the plan requirements (with certain plan details allowing for a delayed compliance date for medium-format batteries, but no later than January 1, 2029, if a delay occurs).

• July 1, 2029: retailer sales prohibition begins unless the producer participates in a BSO with an approved plan.

• June 1, 2029: first annual report due (and each June 1 thereafter).

• January 1, 2030: disposal and collection requirements start, including a landfill disposal prohibition for covered batteries; loose covered batteries must be accepted/managed without charging a fee when delivered/collected for management (fees for battery-containing products are not prohibited by that specific clause).

Who Assumes Responsibility

Producers assume financial responsibility for Colorado battery recycling by funding/participating in a BSO and ensuring compliance for batteries/products placed on the market.
BSOs assume operational responsibility for implementing the statewide program under an approved plan (collection network, transport, processing/recycling, education/outreach, and performance management).
CDPHE assumes regulatory oversight responsibility (plan review/approval, administration, and enforcement under the state hazardous waste enforcement process referenced by the act).
Retailers assume market-access responsibility starting in 2029 by selling only compliant producers’ batteries/products and by not charging prohibited point-of-sale fees.

Duties of Each Group

Producers

• Participate in and finance a BSO (by the effective compliance date) to continue selling/distributing in or into Colorado.

• Ensure products meet marking/labeling requirements starting in 2028 (as applicable).

• Manage producer responsibility allocation for battery-containing products (including certifications/contractual assumptions where used).

Battery stewardship organizations (BSOs)

• Submit stewardship plans on schedule and operate the program under an approved plan.

• Establish free collection opportunities for covered batteries, including statewide convenience requirements (including specific statewide provisions for medium-format batteries).

• Collect dues from participating producers to fund program operations.

• Submit annual reports beginning in 2029 and coordinate required public awareness surveying/reporting.

Retailers

• From July 1, 2029, sell covered batteries/battery-containing products only if the producer participates in a BSO with an approved plan.

• Do not charge a point-of-sale fee to cover BSO/program costs.

Consumers / end users

• From January 1, 2030, manage unwanted covered batteries through delivery to a collection site/event/program established or included in a battery stewardship program; do not dispose of covered batteries in landfills.

Who Is Responsible

If you place portable or medium-format batteries (or products containing/packaged with easily removable covered batteries) on the Colorado market, you are likely the responsible “producer” unless an allowed allocation rule applies (e.g., another party contractually assumes producer responsibility and is acknowledged within a BSO’s approved plan, or a battery-containing product party is excluded because the only batteries are supplied by a participating producer with proper written certification). Retailers become responsible for sales gating starting in 2029.

Additional Information for Consideration

• Colorado’s battery EPR is focused on removable batteries: embedded batteries are explicitly excluded from the “covered battery” definition, so embedded-battery products may fall outside this law’s main producer obligations (unless the product is packaged with easily removable covered batteries).

• Labeling is substantive: the 2028 marking requirement is not just branding—it also requires battery chemistry identification and an indication the battery should not be disposed of as household waste (with a small-battery marking exception).

• The law bans point-of-sale “EPR battery fees”: retailers/producers/BSOs cannot add a POS fee to cover BSO/program costs, so funding must come from producer payments to the BSO.

• Expect rulemaking detail: the Solid and Hazardous Waste Commission is empowered to adopt rules (including around marking requirements and annual fees), and program mechanics will become more operationally specific as CDPHE and the Commission implement the act.

Extended producer responsibility for batteries in United States of America (Maine)
Maine’s battery “EPR-style” requirements are currently narrower than full consumer battery EPR programs seen in some other jurisdictions. Maine law requires manufacturers of certain rechargeable batteries (and certain other dry-cell batteries) to provide a collection system for end-of-life management, and Maine DEP points to Call2Recycle as the program that fulfills this requirement in practice. The environmental authority is the Maine Department of Environmental Protection (Maine DEP) EPR / Waste Management & Recycling program.

Who must register for EPR in United States of America in Maine

Manufacturers/producers: Maine law places responsibility on manufacturers of the covered battery chemistries to ensure a collection system exists for those batteries. Maine does not operate a classic “state producer registration portal” for batteries like some packaging EPR programs; compliance is typically achieved by participating in a manufacturer-sponsored program (most commonly Call2Recycle) or establishing an equivalent collection system.
Business and institutional users: Maine restricts disposal of rechargeable batteries (and certain other specified battery types) by certain non-household users and requires those batteries to be managed through the manufacturer collection system rather than disposed of in trash.

Ready to make extended producer responsibility effortless for USA? Request a personalized EPR fee quote now and start turning regulatory obligations into sustainable value for your brand for cross-border sales!

What the package includes

This is batteries-only (not packaging). Maine’s current producer responsibility requirement is tied to specific battery types covered in state law and referenced by Maine DEP, including rechargeable battery chemistries that Maine’s product stewardship reporting has described as rechargeable nickel-cadmium and rechargeable sealed lead-acid (small sealed lead-acid), and also dry-cell mercuric oxide batteries in the same statutory section. In practice, Maine DEP guidance discusses rechargeable batteries and directs users to a manufacturer collection system (typically Call2Recycle).

Threshold

There is no widely used public “small producer threshold” for Maine’s current rechargeable-battery collection-system requirement. The practical threshold is chemical/type-based scope (i.e., whether you place the covered rechargeable battery types on the Maine market) and user-type restrictions (i.e., which entities are prohibited from disposing of those batteries in trash and must use the collection system).

EPR registration procedure in United States of America in Maine

1. Confirm scope: Determine whether the batteries you place on the Maine market fall under Maine’s covered rechargeable battery types (and any other covered battery types referenced in the same statutory requirement).

2. Determine your compliance route:

   • Join an established stewardship/collection program that fulfills Maine’s requirement (Call2Recycle is the program Maine DEP points to), or

   • Establish an alternative collection system that satisfies the statutory obligation.

3. Operationalize takeback: Ensure you have collection pathways for end users and downstream recycling arrangements consistent with Maine’s expectations.

4. Customer instructions: Provide practical guidance to business/institutional users on how to return batteries through the collection system and reinforce that disposal in trash is prohibited for covered users/batteries.

Authorized representative

Maine’s battery requirements do not use an EU-style authorized representative model. Responsibility is assigned directly through the manufacturer obligation to provide a collection system. Companies commonly appoint a compliance contact or a stewardship provider to manage operational execution, but that is an internal governance choice rather than a statutory “authorized representative” role.

Reporting

Maine’s rechargeable battery requirement is not structured as a modern annual producer reporting-and-fee regime to the state. Instead, the expectation is that manufacturers ensure a compliant collection system exists and that covered users route batteries into that system. If you comply via a stewardship organization (e.g., Call2Recycle), that operator may have its own membership reporting, invoicing, and downstream documentation requirements.

Deadline

Maine’s rechargeable battery collection-system obligation is an ongoing compliance requirement (not a single annual “EPR registration Maine” deadline). Key operational “deadlines” to treat as always-on compliance controls are:

• Batteries in scope (for covered users) must be managed through the collection system rather than disposed of in trash.

• Manufacturers must continuously maintain a functioning collection system (directly or via a stewardship program) while selling covered batteries in Maine.

Who Assumes Responsibility

Manufacturers/producers assume responsibility by ensuring a collection system exists for covered rechargeable batteries (and covered users can access that system).
Covered business/institutional users assume responsibility by using the collection system and not disposing of covered rechargeable batteries in the trash.
Maine DEP assumes oversight responsibility through guidance and enforcement under the applicable waste management and product stewardship framework.

Duties of Each Group

Manufacturers/producers

• Ensure a compliant collection system exists for covered rechargeable batteries sold in Maine (often via a stewardship operator).

• Support accessible return options and practical instructions for users.

Businesses/institutions covered by the disposal restriction

• Segregate covered rechargeable batteries from trash.

• Use the manufacturer collection system (e.g., Call2Recycle) or other compliant recycling arrangements.

Stewardship/collection system operator (if used)

• Provide collection infrastructure, shipping/handling guidance, and downstream recycling management for collected batteries.

Maine DEP (local environmental authority)

• Publishes guidance on battery recycling requirements and acceptable collection pathways; conducts policy development (including evaluating whether to expand EPR to additional battery types).

Who Is Responsible

If you manufacture (or are otherwise the responsible producer for) covered rechargeable batteries sold in Maine, you are responsible for ensuring a collection system exists (commonly fulfilled through Call2Recycle). If you are a covered business/institutional user generating spent rechargeable batteries, you are responsible for keeping them out of trash and managing them through the collection system or equivalent compliant recycling route.

Additional Information for Consideration

• Maine DEP has indicated it is evaluating the feasibility/viability of establishing an extended producer responsibility approach for batteries not currently covered by the existing rechargeable-battery stewardship requirement, which could expand Maine battery EPR scope in the future.

• Practical risk driver: battery fires and mishandling risks are a major operational concern for waste and recycling systems; battery collection programs often emphasize safe storage/handling and proper segregation.

• If your products contain embedded (non-user-removable) batteries, Maine’s current rechargeable-battery collection-system requirement may not capture those products the same way a “full consumer battery EPR” law would—so scope mapping should distinguish loose/easily removable batteries vs embedded batteries.

This guide covers battery obligations in Minnesota Battery EPR . Minnesota’s battery producer-responsibility framework is primarily built around rechargeable batteries and products powered by rechargeable batteries, overseen by the Minnesota Pollution Control Agency (MPCA) EPR. Minnesota also has a separate manufacturer responsibility requirement for certain dry cell batteries (specific chemistries) when those batteries are purchased for use or used by government agencies and certain facilities.

Who must register for Battery EPR in Minnesota

Minnesota does not run a classic “producer registration portal” for batteries. Instead, battery compliance is achieved by operating or joining a compliant collection/recycling program and meeting statutory sale/notice requirements. Parties in scope include:

• Manufacturers of rechargeable batteries sold in Minnesota.

• Manufacturers of products powered by rechargeable batteries, including products with nonremovable rechargeable batteries and products powered by rechargeable batteries/battery packs.

• Retailers/resellers (market access duties): rechargeable batteries and covered products that don’t meet the collection requirements cannot be sold in Minnesota by manufacturers or resellers, and retailers must post a consumer notice at retail for rechargeable batteries/products covered by the rechargeable battery law.

• Manufacturers of certain dry cell batteries (mercuric oxide electrode, silver oxide electrode, nickel-cadmium, sealed lead-acid) purchased for use or used by specified entities (government agencies; industrial, communications, or medical facilities).

What the package includes

Minnesota’s battery EPR-style scope is electronics/batteries, not packaging. Key coverage includes:

• Rechargeable batteries: defined to include sealed nickel-cadmium, sealed lead-acid, and other rechargeable batteries (unless governed by the separate dry-cell section or exempted by MPCA).

• Rechargeable battery packs and products powered by rechargeable batteries/battery packs, including products with nonremovable rechargeable batteries (these are also covered by Minnesota’s disposal prohibition for mixed municipal solid waste).

• Rechargeable consumer products (tools/appliances and other household products): Minnesota restricts sales unless the battery is easily removable (or in an easily removable battery pack) and both product and battery are labeled with recycling/disposal and electrode-type information (unless MPCA grants a limited exemption).

• Certain dry cell batteries used by specific facilities: a separate rule prohibits disposal of certain chemistries in mixed municipal solid waste when used by the specified entities and requires manufacturers to ensure a collection/processing system exists for those purchasers.

Threshold

Minnesota’s battery framework is scope-based, not a typical volume/turnover threshold model:

• If you sell rechargeable batteries or products powered by rechargeable batteries in Minnesota, you should assume you are in scope and must ensure compliant collection is in place to maintain market access.

• The “certain dry cell batteries” obligations are triggered by battery chemistry and end-user category (government agencies; industrial/communications/medical facilities), not by sales volume.

EPR registration procedure in United States of America in Minnesota 

Because Minnesota does not run a single statewide “EPR registration United States of America” portal for batteries, the practical compliance procedure is program-based:

1. Scope mapping

• Confirm whether your batteries/products fall under Minnesota’s rechargeable battery rules, rechargeable consumer product removability/labeling rules, and/or the “certain dry cell batteries” facility-use rules.

2. Choose a compliance route for rechargeable batteries/products

• Become a licensee of an established collection program (MPCA specifically points to Call2Recycle as a pathway), or

• Create and operate your own collection/recycling program.

3. If operating your own program, document a plan
   MPCA recommends a structured plan (updated every five years) that covers program design, start date, chemistries sold and recycled, promotion, collection sites, logistics/processing partners, performance measurement, and how you will work toward Minnesota’s statutory expectation to collect a high share of rechargeable batteries by weight.

4. Ensure market access controls

• Maintain compliant collection coverage so manufacturers and resellers can lawfully sell rechargeable batteries/products in Minnesota.

• Ensure rechargeable consumer products meet removability/labeling requirements (or qualify for a limited MPCA exemption).

• Ensure retailers receive the information they need to meet the retail notice requirement.

5. For facility-use “certain dry cell batteries”

• Ensure a system exists for proper collection/transport/processing for Minnesota purchasers in scope, and provide purchaser instructions (including a contact telephone number) explaining the disposal prohibition and how to manage returns.

Authorized representative

Minnesota does not use an EU-style “authorized representative” concept for batteries. However, Minnesota law allows manufacturers to meet rechargeable battery obligations through a representative organization (an industry program) that operates collection and can report aggregated results for its members. In practice, this is how many producers operationalize compliance.

Reporting

Rechargeable batteries/products

• In odd-numbered years, manufacturers (or a representative organization) must report rechargeable battery sales and collection information covering the previous two years. MPCA’s guidance specifies reporting is provided in pounds sold and collected in Minnesota and includes where to submit the report.

Facility-use “certain dry cell batteries”

• The statute is structured around ensuring a collection/processing system exists and that purchasers are clearly informed of disposal prohibitions and return procedures. While not framed as a routine annual “producer report,” companies should maintain internal documentation showing the system and communications are in place.

Deadline

Rechargeable batteries/products

• Minnesota’s disposal prohibition for rechargeable batteries and certain rechargeable-battery-powered products has been in place for decades.

• MPCA’s current reporting instruction: odd-numbered years, by March 31, for the preceding two-year period.

Retail notice

• Retailers selling rechargeable batteries/products covered by the rechargeable battery law must post the required consumer notice at retail (the law specifies minimum notice size and content).

Facility-use “certain dry cell batteries”

• Ongoing obligation: manufacturers must continuously ensure a compliant collection/processing system exists for covered purchasers and provide purchaser instructions at the time of sale/transfer.

Duties of Each Group Who Is Responsible

Manufacturers (rechargeable batteries and rechargeable-powered products)

• Assume financial responsibility for collection and management so covered batteries/products are not disposed in the solid waste stream.

• Ensure a compliant collection program is in place (directly or via a representative organization).

• Ensure rechargeable consumer products meet removability and labeling requirements (or obtain a limited MPCA exemption).

• Submit required reporting in odd-numbered years (or ensure the representative organization does so).

Manufacturers (certain dry cell batteries for covered purchasers)

• Ensure a collection/transport/processing system exists for Minnesota purchasers in scope.

• Inform purchasers of the disposal prohibition and how to use the system (including a telephone contact).

Retailers / resellers

• Must not sell rechargeable batteries/products that do not meet the collection requirements (market access dependence).

• Must display the required consumer notice for rechargeable batteries/products covered by the rechargeable battery law.

Who Is Responsible

If you place rechargeable batteries or products powered by rechargeable batteries on the Minnesota market, you are typically the responsible party for Minnesota’s battery producer-responsibility requirements, and maintaining compliant collection is essential for lawful sales. If you place covered facility-use dry cell batteries on the market for the specified purchaser categories, you are responsible for ensuring an appropriate collection/processing system exists and for communicating disposal and return procedures to purchasers.

Additional Information for Consideration

• MPCA has authority to exempt new rechargeable battery types from the rechargeable battery requirements if they pose no unreasonable hazard in the mixed municipal solid waste stream—this can matter for emerging chemistries and product designs.

• Minnesota’s framework is not a modern “all batteries” EPR program (e.g., it is not a broad, producer-funded takeback for all household primary batteries). It is strongest for rechargeable batteries and certain facility-use dry cell chemistries, plus product design/labeling and retail notice requirements.

• If you manage multiple product EPR programs nationally, you may need to coordinate Minnesota batteries compliance alongside EPR United States of America programs in other categories. (Separately, many companies manage EPR packaging United States of America and United States of America packaging recycling obligations in other states; just don’t confuse those packaging EPR systems with Minnesota’s battery-specific rules.)

• Operational tip: battery collection and transport safety is increasingly critical (especially for lithium-based chemistries). Even where not explicitly spelled out as “EPR,” downstream partners often require safe packaging/terminal protection and clear acceptance rules—build that into collection instructions and vendor SOPs.

Washington State has adopted a statewide battery EPR framework under Chapter 70A.555 RCW (Batteries—Environmental Stewardship), implemented through Chapter 173-905 WAC (Battery Stewardship Program). The program is designed to provide free, convenient battery drop-off for residents and is funded by battery “producers” through approved battery stewardship plans administered by the Washington State Department of Ecology EPR program.
This batteries-only guide is separate from EPR packaging United States of America and United States of America packaging recycling rules (which are addressed under different state laws and programs).

Who must register for EPR in United States of America in Washington State

There is no single state “producer registry” label in the law, but producers must participate in an Ecology-approved stewardship plan (effectively the EPR registration United States of America step for Washington batteries). In scope parties include:

• Producers of covered batteries and battery-containing products sold, offered for sale, or distributed “in or into” Washington State (producer is determined by brand/manufacturer/brand owner/importer/first in-state seller fallback rules).

• Battery stewardship organizations (a producer acting alone, or a nonprofit designated by producers) that submit and operate the approved plan.

• Retailers selling covered batteries or battery-containing products in Washington (retail sales restrictions apply beginning in 2027/2029 depending on battery type).

• Consumers / all persons (proper disposal requirements apply once the program starts on the statutory timelines).

What the package includes

Washington’s program covers:

• Covered batteries:

  • Portable batteries (primary ≤ 4.4 lbs; rechargeable ≤ 11 lbs and ≤ 300 Wh).

  • Medium format batteries become covered starting January 1, 2029 (primary > 4.4 lbs up to 25 lbs; rechargeable > 11 lbs or > 300 Wh up to 25 lbs and ≤ 2,000 Wh).

• Battery-containing products that contain (or are packaged with) covered batteries, with an important exclusion: a battery-containing product does not include a “covered electronic product” already managed under Washington’s e-cycle program.
  Key exclusions from “covered battery” include (among others): certain batteries in medical devices not marketed principally to consumers for personal use; batteries with free-liquid electrolyte; lead-acid batteries > 11 lbs; batteries already subject to specific other Washington RCWs; and batteries in products not intended/designed to be easily removable by the consumer.

Threshold

Washington’s battery EPR obligations are not based on a weight/turnover threshold for producers. Instead, obligations apply if you qualify as the producer of a “covered battery” or “covered battery-containing product” sold into Washington.
Operationally, Washington uses battery size categories (portable vs. medium format vs. large format) and phase-in dates to determine when requirements start, rather than a de minimis sales threshold.

EPR registration procedure in United States of America Washington State

Practical steps to comply with Washington’s battery EPR program:

1. Determine if you are the “producer”
   Apply Washington’s producer hierarchy (manufacturer → brand owner → licensee → importer of record → first seller with commercial presence in Washington) for each covered battery brand and each covered battery-containing product brand.

2. Join or establish a battery stewardship organization
   Producers must participate in an approved Washington battery stewardship plan via a stewardship organization (or operate an individual plan).

3. Plan submission and approval

• A stewardship plan for portable batteries must be submitted by July 1, 2026 (or within six months of rule adoption, whichever is later).

• A stewardship plan for medium format batteries must be submitted within 24 months of initial rule adoption.
  Plans must include required elements such as participating producers/brands, funding approach, collection site network and convenience standard approach, safety procedures (including fire/spill response), education/outreach, and end-of-life management approach aligned with the battery management hierarchy.

4. Prepare for the “market access” rules
   Beginning July 1, 2027 (portable) and July 1, 2029 (medium format), retailers may only sell covered batteries/battery-containing products if the producer participates in an approved plan. Retailers can rely on Ecology’s published list of participating producers/brands.

5. Ongoing compliance: fees, reporting, and program operations
   Battery stewardship organizations fund program operations and pay Ecology’s annual oversight fees established by rule, and must meet performance, reporting, convenience, and outreach requirements.

Authorized representative

Washington’s battery EPR law does not create a formal “authorized representative” role (unlike some EU EPR systems). Producers typically comply by joining a battery stewardship organization that manages plan submission, program operations, reporting, and stakeholder coordination.

Reporting

Battery stewardship organizations must submit an annual report to Ecology starting June 1, 2028, and each June 1 thereafter, covering the preceding calendar year. Reporting includes financial transparency requirements and other program performance information as specified in law and rules.

Deadline

Key compliance dates for Washington batteries:

• January 16, 2026: Chapter 173-905 WAC becomes effective (rule implementing the program).

• July 1, 2026: portable battery stewardship plan submission deadline (or later trigger if applicable under the statute’s rule-adoption timing).

• January 1, 2027: producers must participate in an approved stewardship plan to sell covered batteries/battery-containing products into Washington.

• July 1, 2027: retailer sales restriction begins for portable batteries and portable-battery-containing products; consumer disposal requirements also begin (or when the first plan is implemented—whichever comes first under the statute).

• January 1, 2028: marking requirements begin for covered batteries / certain battery-containing products (producer identification marking); additional labeling requirements phase in later.

• January 1, 2029: medium format batteries become “covered batteries.”

• July 1, 2029: retailer sales restriction and consumer disposal requirements begin for medium format batteries.

• June 1, 2028: first annual report due from stewardship organizations.

Who Assumes Responsibility

Producers (primary responsibility)

• Finance and participate in an Ecology-approved stewardship plan for covered batteries and covered battery-containing products sold into Washington.

• Ensure products remain eligible for retail sale in Washington once the retailer restrictions begin.

• Meet marking/labeling requirements on applicable batteries (directly or via the supply chain, depending on role).

Battery stewardship organizations (operational responsibility)

• Submit stewardship plans, operate statewide collection networks, ensure safe handling and end-of-life management, deliver education/outreach, and report annually to Ecology.

• Collect all covered battery chemistries and brands on a free, continuous, convenient, visible, and accessible basis, consistent with plan and statutory requirements.

Retailers

• Starting in 2027/2029 (depending on battery type), only sell covered batteries/battery-containing products from producers participating in an approved plan (with reliance on Ecology’s published list).

• Ensure covered batteries sold are properly marked as required.

• May provide stewardship-program educational materials voluntarily; cannot charge a visible point-of-sale fee to consumers to cover stewardship program costs.

Consumers / “all persons”

• Once effective, must dispose of unwanted covered batteries using: the stewardship program’s collection sites, compliant hazardous/solid waste pathways for regulated generators, or qualifying local government collection facilities.

Who Is Responsible

• If you place covered batteries or covered battery-containing products on the Washington market and meet the statutory “producer” definition, you are responsible for compliance (via an approved stewardship plan).

• Battery stewardship organizations are responsible for plan operation, collection system delivery, and reporting.

• Retailers are responsible for “market access” checks and marking-related sales conditions once deadlines apply.

Additional Information for Consideration

• Scope is broader than “where purchased”: Washington’s rules emphasize statewide collection convenience and apply to batteries used in Washington, not just those bought in-state (important for e-commerce and national distribution models).

• Medium format is phased-in later: build separate readiness tracks for portable batteries (2026–2027 timeline) vs. medium format batteries (2029 market restrictions).

• Design + labeling strategy: marking starts in 2028 and additional “proper labeling” requirements phase in later—align packaging/artwork change windows early to avoid stranded inventory.

• Cross-program overlaps: battery-containing products that qualify as “covered electronic products” under Washington’s e-cycle program are excluded from the battery-containing product definition here—map product categories carefully to avoid double-counting.

• Keep the SEO storyline coherent across your US content: if you maintain a broader US hub page, link Washington batteries content alongside EPR United States of America, while keeping it distinct from EPR packaging United States of America and United States of America packaging recycling compliance content.

Extended Producer Responsibility (EPR) in the United States is regulated at the state level, not federally. In California, EPR obligations for chemical products are implemented through product-specific stewardship programs, rather than a single comprehensive EPR law.

The regulatory oversight of EPR in California is primarily shared between CalRecycle and the California Department of Toxic Substances Control (DTSC), depending on the chemical category.

Who must register for Chemicals EPR in United States California

Under EPR United States (California), registration obligations apply to producers, manufacturers, brand owners, and importers of certain chemical-containing products placed on the California market.

Entities required to register typically include:

• Manufacturers of regulated chemical products sold in California

• Importers bringing chemical products into California

• Brand owners whose names appear on chemical product labels

• Distributors acting as the first entity placing regulated chemicals on the California market

Registration obligations are product-specific, meaning a company may be subject to EPR registration for one chemical product category but not others.

• Ready to make extended producer responsibility effortless for USA? Request a personalized EPR fee quote now and start turning regulatory obligations into sustainable value for your brand for cross-border sales!

What the package includes

For chemical-focused EPR programs in California, the “package” generally includes:

• The chemical product itself

• The primary container holding the chemical

• Associated consumer-use packaging, where applicable

While California packaging recycling laws (such as SB 54) focus on consumer packaging, chemical EPR programs prioritize:

• Safe collection

• Transportation

• Treatment

• Recycling or disposal of chemical products and containers

This distinction is critical when assessing EPR registration United States obligations for chemical producers.

Threshold

California chemical EPR programs typically do not rely on volume-based thresholds in the same way as packaging EPR systems in Europe.

Instead, thresholds are defined by:

• Product type (e.g., paint, pharmaceuticals)

• Market participation (placing products on the California market)

• Role in the supply chain

Even small-volume producers may be obligated to comply if they place regulated chemical products into California commerce.

EPR registration procedure in United States in California

The EPR registration United States process for chemical products generally follows these steps:

1. Identify whether the chemical product falls under a regulated stewardship program

2. Register with the relevant authority or approved stewardship organization

3. Join or establish a Producer Responsibility Organization (PRO) where required

4. Submit compliance plans outlining collection, recycling, and disposal methods

5. Pay applicable stewardship or administrative fees

Registration is overseen by CalRecycle or DTSC, depending on the chemical category.

Authorized representative

Non-U.S. companies placing chemical products on the California market are strongly encouraged, and in some cases required, to appoint an authorized U.S. representative.

The authorized representative acts as:

• The legal compliance contact

• The reporting and communication liaison with CalRecycle or DTSC

• The entity responsible for documentation and audit support

This requirement is particularly relevant for international producers unfamiliar with EPR United States regulations.

Reporting

Producers subject to chemical EPR obligations must submit periodic reports, typically on an annual basis, detailing:

• Quantities of products placed on the California market

• Collection and take-back performance

• Recycling, treatment, or disposal outcomes

• Consumer education and outreach activities

Reporting formats and timelines vary by stewardship program and administering authority.

Deadline

Deadlines under California chemical EPR programs are program-specific and may include:

• Annual registration renewals

• Annual performance and financial reports

• Plan updates following regulatory changes

Failure to meet deadlines may result in administrative penalties, sales prohibitions, or enforcement actions.

Who Assumes Responsibility

Responsibility under EPR United States (California) is assigned as follows:

• Producers / Brand Owners: Primary legal responsibility for compliance, financing, and reporting

• Importers: Responsible when no U.S.-based producer exists

• Producer Responsibility Organizations (PROs): Operational execution of collection and recycling programs

• Retailers: Limited obligations, mainly related to consumer information and take-back participation

Additional Information for Consideration

• California does not currently have a unified chemical EPR law, but expansion of stewardship programs is ongoing

• Chemical producers may be subject to both EPR and hazardous waste regulations simultaneously

• Compliance with California EPR does not guarantee compliance in other U.S. states

• Data transparency and audit readiness are increasingly emphasized by CalRecycle EPR enforcement

• Companies involved in chemical products should monitor legislative developments, as California often sets precedents later adopted nationwide

In Maryland, “EPR” for chemicals is implemented mainly through product-specific stewardship and producer registration regimes (often called product stewardship / take-back laws), not through one single “chemicals EPR” framework. The most established producer-responsibility style programs in Maryland that are relevant to chemical or chemically hazardous products include architectural paint (Paint Stewardship) and electronics (Maryland eCycling)—both overseen by the Maryland Department of the Environment (MDE).

Maryland also regulates several mercury-related products via sales prohibitions and labeling requirements, and it operates broader Household Hazardous Waste (HHW) collection infrastructure at the county level. Separate proposals have been introduced to create EPR for other chemical product categories (notably batteries and drug manufacturer take-back), but they are not currently in force statewide as “EPR” obligations for producers.

Who must register for EPR in Maryland

• Architectural paint (Paint Stewardship): Producers of architectural paint (or a representative organization acting on their behalf) must participate via an approved program plan and brand registration mechanism in Maryland (commonly through PaintCare).

• Electronics (Maryland eCycling): Manufacturers of covered electronic devices (CEDs) must register with MDE to sell or offer CEDs for sale in Maryland (chemical relevance: electronics frequently contain hazardous constituents such as heavy metals and other regulated substances).

• Mercury-added products: Maryland imposes requirements and restrictions (e.g., labeling and sales bans for certain mercury-added products; thermostat sales restrictions). These are compliance obligations for manufacturers/retailers, but they are not always structured as an EPR take-back duty.

If you sell chemical products in Maryland, you generally become “EPR-relevant” when your products fall into one of the covered product categories above (paint, electronics, etc.), rather than simply because a product contains “chemicals.”

Ready to make extended producer responsibility effortless for USA? Request a personalized EPR fee quote now and start turning regulatory obligations into sustainable value for your brand for cross-border sales!

What the package includes

Because Maryland’s chemicals-related producer obligations are category-based, “the package” is best understood as the scope of each covered program:

• Paint Stewardship: covered architectural paint and the system required to manage postconsumer paint (collection network, transport, processing, consumer education, and program financing).

• Electronics (eCycling): covered electronic devices, manufacturer registration, and (depending on the manufacturer’s approach) free take-back/recycling options tied to brand registration and compliance.

• Mercury-related rules: covered mercury-added products subject to labeling requirements and/or sales prohibitions (for certain categories).

Threshold

Maryland’s producer responsibility obligations in these chemicals-adjacent categories generally do not rely on simple tonnage thresholds (e.g., “X tonnes/year”) the way some EU EPR regimes do.

Instead, obligations are typically triggered by:

• Whether you are a producer/manufacturer of a covered product sold or offered for sale in Maryland; and/or

• Whether you are a manufacturer of a covered electronic device registering to sell into the state; and/or

• Whether you sell products in categories subject to sales bans / labeling requirements (e.g., certain mercury-added products).

EPR registration procedure in United States

A practical EPR registration United States (Maryland) pathway for chemicals is:

1. Classify the product category (architectural paint, covered electronics, mercury-added product categories).

2. Identify the responsible authority/program operator:

   • Maryland Department of the Environment (MDE) for paint plan oversight and electronics manufacturer registration.

   • PaintCare as the representative organization implementing the paint program (for participating producers/brands).

3. Register / enroll as required:

   • Paint: ensure producer participation and brand registration through the program mechanism used in Maryland.

   • Electronics: register as an eManufacturer with MDE (and meet labeling/brand requirements).

4. Meet operational obligations (collection/take-back availability where required, consumer information, and any plan requirements).

5. Report and maintain compliance (annual reporting where required; keep registration current; respond to MDE requests).

Authorized representative

Maryland’s laws are generally written in terms of producer/manufacturer responsibility and do not consistently require a formal “authorized representative” the way many EU EPR systems do.

However, for non-U.S. producers (or complex corporate groups), it is best practice to appoint a U.S. compliance contact to:

• Interface with MDE and program operators (e.g., PaintCare),

• Manage reporting, notices, and documentation,

• Coordinate responses to enforcement or retailer compliance checks (particularly relevant where sales restrictions apply).

Reporting

Reporting obligations depend on the covered product category:

• Paint Stewardship: programs typically require periodic reporting (commonly annual) covering program performance, collection network coverage, and volumes managed, aligned with the program plan structure overseen by MDE.

• Electronics (eCycling): manufacturers maintain registration status and may provide compliance documentation; MDE publishes registered/approved manufacturer lists for defined periods.

• Mercury-added product compliance: reporting may be less “EPR-style” and more compliance/labeling-oriented, depending on product type.

Deadline

Key Maryland milestones that matter for chemicals-related producer responsibility include:

• Paint Stewardship Program plan submission deadline set in Maryland’s paint stewardship law framework (with MDE plan review/approval and sales prohibition mechanics tied to implementation dates).

• Electronics manufacturer registration must be in place before selling/ offering covered electronic devices in Maryland (brand labeling and registration are linked to the ability to sell).

• Batteries and drug manufacturer take-back: Maryland has seen legislative proposals to create producer take-back obligations, but those proposals’ deadlines should not be treated as compliance dates unless enacted.

Who Assumes Responsibility

In EPR United States Maryland (chemicals/product stewardship context), responsibility usually sits with:

• Producers / Manufacturers / Brand owners

  • Primary obligation to participate in the applicable program (paint) and/or register (electronics), and ensure lawful sales in Maryland.

• Representative organizations / program operators

  • For paint, a representative organization (e.g., PaintCare) runs collection networks, outreach, logistics, and reporting on behalf of participating producers, consistent with the approved program plan.

• Retailers

  • Often affected through sell-through conditions (e.g., selling only compliant/registered brands in certain regimes) and may volunteer as collection sites where programs are built that way.

• Maryland Department of the Environment (MDE)

  • Oversight authority—plan review/approval (paint), manufacturer registration administration and public lists (electronics), and broader compliance functions in covered areas.

Additional Information for Consideration

• Maryland’s “chemicals EPR” is not one law: compliance is best handled via a product-mapping approach (SKU/category → Maryland program → registration/enrollment → reporting cadence).

• Paint is the clearest chemicals-adjacent EPR in Maryland (through architectural paint stewardship), with an explicit program plan structure and an implementation timeline communicated through program materials.

• Electronics EPR is highly operational in Maryland: MDE maintains registered/approved manufacturer lists for defined periods; this is a strong enforcement mechanism tied to market access.

• Mercury rules matter even when not “EPR”: Maryland’s mercury-related restrictions (labeling/sales bans for certain product types, thermostat sales ban references) can impact product design, labeling, and retail compliance—even without a formal take-back mandate.

• Household Hazardous Waste (HHW) is not EPR: county HHW programs accept many chemical wastes (paint, pesticides, batteries, etc.), but HHW collection is generally a public service model unless a specific producer stewardship law applies.

• Don’t confuse packaging EPR with chemicals stewardship: Maryland’s chemicals obligations are separate from United States packaging recycling frameworks (where those exist in other states); for Maryland chemicals, focus on the product categories above.

Minnesota does not have a single, horizontal “chemicals EPR” law. Instead, it operates multiple long-standing, product-specific EPR and stewardship programs that apply to chemical or hazardous product categories, most notably architectural paint, pharmaceuticals, mercury-added products, pesticides containers, electronics, and batteries. These programs are primarily overseen by the Minnesota Pollution Control Agency (MPCA).

Extended producer responsibility for packaging in United States - Minnesota

Extended Producer Responsibility (EPR United States – Minnesota) for chemicals is implemented through category-specific stewardship and take-back laws, rather than a single chemicals EPR framework. Minnesota is one of the earliest U.S. adopters of product stewardship laws and has comprehensive producer responsibility obligations for several chemical or hazardous product streams.

The primary competent authority is the Minnesota Pollution Control Agency (MPCA), which oversees program approvals, reporting, and enforcement. These EPR programs are designed to:

• Reduce improper disposal of chemical products

• Shift end-of-life management costs from municipalities to producers

• Protect human health and the environment

Who must register for EPR in Minnesota

For EPR United States (Minnesota) focused on chemicals, registration and participation obligations depend on the covered product category:

• Architectural paint: Manufacturers (or their representative organization) selling architectural paint in Minnesota must participate in the state’s paint stewardship program.

• Pharmaceuticals (drug take-back): Manufacturers of covered drugs sold into Minnesota must participate in a statewide drug stewardship program.

• Electronics (hazardous constituents): Manufacturers of covered electronic devices must register with MPCA and comply with Minnesota’s electronics recycling law.

• Mercury-added products: Manufacturers of mercury-added products (e.g., lamps, thermostats) must comply with Minnesota’s mercury product restrictions and stewardship requirements.

• Pesticide containers: Pesticide manufacturers and distributors are subject to container management and recycling requirements under Minnesota rules.

• Batteries: Minnesota regulates certain batteries through stewardship and disposal restrictions, with producer involvement in collection systems.

If you place covered chemical products on the Minnesota market, you are likely subject to EPR registration United States (Minnesota) for that product category.

Ready to make extended producer responsibility effortless for USA? Request a personalized EPR fee quote now and start turning regulatory obligations into sustainable value for your brand for cross-border sales!

What the package includes

Because Minnesota’s chemicals EPR is program-specific, the “package” generally includes:

• The covered chemical product (e.g., paint, pharmaceuticals, mercury lamps)

• The end-of-life management system, including:

  • Collection and take-back infrastructure

  • Transportation and processing

  • Recycling, treatment, or disposal

  • Consumer education and outreach

• In some cases, sales restrictions if producers are not compliant

Packaging itself is not the primary regulated element in Minnesota’s chemicals EPR programs unless explicitly stated in a given statute.

Threshold

Most Minnesota chemical stewardship programs do not rely on tonnage or revenue thresholds.

Obligations are generally triggered by:

• Being a manufacturer/brand owner of a covered product

• Offering that product for sale in or into Minnesota

• Meeting the statutory definition of a covered product

This means small-volume sellers may still be obligated to comply.

EPR registration procedure in United States

A typical EPR registration United States (Minnesota) process for chemicals includes:

1. Product classification – Identify whether your product is covered under Minnesota stewardship laws.

2. Authority identification – Determine the applicable MPCA-administered program or approved stewardship organization.

3. Registration or enrollment – Register with MPCA or join an approved stewardship organization (e.g., PaintCare for paint).

4. Program financing – Pay required fees or assessments to fund collection and processing.

5. Operational compliance – Meet collection coverage, consumer information, and performance requirements.

6. Ongoing reporting – Submit required reports and maintain documentation.

Authorized representative

Minnesota statutes generally refer to manufacturers, producers, or brand owners and do not explicitly require an “authorized representative” in the EU sense.

However, non-U.S. producers selling chemical products into Minnesota are strongly advised to appoint a U.S. compliance representative to:

• Interface with MPCA EPR programs

• Manage reporting and fee payments

• Respond to enforcement actions or audits

This is especially relevant where responsibility may shift to an importer.

Reporting

Reporting obligations vary by product category but commonly include:

• Quantities of covered products sold or collected

• Collection and recycling performance metrics

• Description of collection network coverage

• Consumer education activities

• Financial reporting related to program funding

Reports are typically annual and submitted to MPCA or via the approved stewardship organization.

Deadline

Minnesota does not have a single chemicals EPR deadline. Instead, deadlines are program-specific, such as:

• Annual reporting deadlines for paint and drug stewardship programs

• Registration renewal deadlines for electronics manufacturers

• Compliance deadlines tied to sales prohibitions for mercury-added products

Failure to meet deadlines can result in:

• Administrative penalties

• Removal from approved manufacturer lists

• Restrictions on product sales in Minnesota

Who Assumes Responsibility? Duties of Each Group Who Is Responsible

Under EPR United States Minnesota, responsibility is typically allocated as follows:

• Manufacturers / Brand Owners

  • Primary legal responsibility for compliance

  • Registration, reporting, and financing obligations

• Importers

  • Assume responsibility when the manufacturer lacks U.S. presence

• Stewardship organizations

  • Operate collection, recycling, education, and reporting systems

• Retailers

  • Must avoid selling non-compliant products where sale restrictions apply

• Minnesota Pollution Control Agency (MPCA)

  • Program oversight, enforcement, and rulemaking

Additional Information for Consideration

• Minnesota is considered a leader in U.S. product stewardship, with some of the earliest EPR-style laws for chemicals.

• Paint and pharmaceuticals represent the most mature chemicals EPR programs in the state.

• Minnesota often expands stewardship obligations incrementally, making regulatory monitoring essential.

• Compliance with Minnesota chemicals EPR does not ensure compliance in other U.S. states.

• Companies should map products SKU-by-SKU to applicable Minnesota stewardship programs.

Oregon does not operate a single, horizontal “chemicals EPR” law. Instead, Oregon has one of the most mature and comprehensive product-specific EPR systems in the U.S., covering several chemical or hazardous product categories, including architectural paint, pharmaceuticals, batteries, mercury-added products, pesticides containers, and electronics. These programs are primarily overseen by the Oregon Department of Environmental Quality (DEQ).

Extended producer responsibility for packaging in United States Oregon

Extended Producer Responsibility (EPR United States – Oregon) for chemicals is implemented through product-specific stewardship and take-back laws, rather than a single chemicals EPR framework. Oregon is widely regarded as a U.S. leader in product stewardship, having enacted some of the earliest and most comprehensive EPR-style laws for hazardous and chemical products.

The competent authority for most chemical EPR programs is the Oregon Department of Environmental Quality (DEQ). These programs aim to:

• Reduce improper disposal of chemical and hazardous products

• Protect human health and the environment

• Shift end-of-life management costs from local governments to producers

Who must register for EPR in Oregon

Under EPR United States in Oregon for chemicals, registration and participation obligations depend on the covered product category:

• Architectural paint: Manufacturers (or a representative organization acting on their behalf) selling architectural paint in Oregon must participate in the state-approved paint stewardship program.

• Pharmaceuticals (drug take-back): Manufacturers of covered drugs sold in or into Oregon must participate in an approved drug stewardship program.

• Batteries: Under Oregon’s Battery Stewardship Act, producers of most battery types sold in Oregon must participate in a producer-funded battery stewardship program.

• Electronics: Manufacturers of covered electronic devices must comply with Oregon’s electronics stewardship requirements.

• Mercury-added products: Manufacturers of mercury-added products (e.g., lamps, thermostats, measuring devices) must comply with Oregon’s mercury product stewardship and restrictions.

• Pesticide containers: Pesticide manufacturers and distributors are subject to container management and recycling requirements.

If you place covered chemical products on the Oregon market, you are likely subject to EPR registration United States (Oregon) for that product category.

• Ready to make extended producer responsibility effortless for USA? Request a personalized EPR fee quote now and start turning regulatory obligations into sustainable value for your brand for cross-border sales!

What the package includes

Because Oregon’s chemicals EPR is program-specific, the “package” generally includes:

• The covered chemical product itself

• The statewide stewardship system, including:

  • Collection and take-back infrastructure

  • Transportation and processing

  • Recycling, treatment, or disposal

  • Consumer education and outreach

• In some programs, sales prohibitions if producers are not compliant

Packaging is not the primary regulated element unless expressly included in a given product-specific law.

Threshold

Most Oregon chemical stewardship programs do not use tonnage, revenue, or sales thresholds.

Obligations are triggered by:

• Being a manufacturer/producer/brand owner of a covered product

• Selling or offering that product for sale in or into Oregon

• Meeting the statutory definition of a covered product

As a result, even low-volume producers may be obligated to comply.

EPR registration procedure in United States

A typical EPR registration United States (Oregon) workflow for chemicals is:

1. Product classification – Determine whether your product is covered by an Oregon stewardship law (paint, drugs, batteries, mercury products, etc.).

2. Authority identification – Identify the applicable Oregon DEQ program or approved stewardship organization.

3. Registration / enrollment – Register with DEQ or enroll via the approved program operator (e.g., PaintCare for paint).

4. Program financing – Pay required stewardship fees or assessments to fund collection and processing.

5. Operational compliance – Meet collection coverage, consumer information, and performance requirements.

6. Ongoing reporting – Submit periodic reports and maintain compliance documentation.

Authorized representative

Oregon statutes typically assign responsibility to manufacturers or producers and do not formally require an EU-style “authorized representative.”

However, non-U.S. producers selling chemical products into Oregon are strongly encouraged to appoint a U.S. compliance representative to:

• Interface with Oregon DEQ EPR programs

• Manage reporting, registration, and fee payments

• Respond to enforcement actions or audits

This is particularly important where responsibility may shift to an importer.

Reporting

Reporting obligations vary by product category but generally include:

• Quantities of covered products sold or collected

• Collection network coverage and accessibility

• Recycling, treatment, or disposal outcomes

• Consumer education and outreach activities

• Financial and performance reporting

Reports are typically annual and submitted to Oregon DEQ or through the approved stewardship organization.

Deadline

Oregon does not impose a single chemicals EPR deadline. Instead, deadlines are program-specific, including:

• Annual reporting deadlines for paint, drug, and battery stewardship programs

• Registration and compliance deadlines tied to market access

• Enforcement-linked deadlines for mercury-added product restrictions

Failure to comply can result in:

• Administrative penalties

• Removal from approved producer lists

• Prohibition on selling covered products in Oregon

Who Assumes Responsibility

Under EPR United States Oregon, responsibility is generally allocated as follows:

• Manufacturers / Brand Owners

  • Primary legal responsibility for registration, financing, and reporting

• Importers

  • May assume responsibility if the manufacturer lacks U.S. presence

• Stewardship organizations

  • Operate collection, recycling, education, and reporting systems

• Retailers

  • Must avoid selling non-compliant products where sale restrictions apply

• Oregon Department of Environmental Quality (DEQ)

  • Program oversight, enforcement, and rulemaking

Additional Information for Consideration

• Oregon is often used as a model state for chemicals and hazardous product stewardship in the U.S.

• Battery stewardship is one of the most significant recent expansions of chemicals EPR in Oregon.

• Compliance with Oregon chemicals EPR does not guarantee compliance in other states.

• Companies should map products SKU-by-SKU to Oregon’s stewardship programs.

• Oregon’s enforcement relies heavily on market access restrictions, making early registration critical.

Ready to make extended producer responsibility effortless for USA? Request a personalized EPR fee quote now and start turning regulatory obligations into sustainable value for your brand for cross-border sales!