What is Alabama EPR EEE

As of March 2026, Alabama remains one of the states without a dedicated Extended Producer Responsibility (EPR) or mandatory "take-back" law for electronics. Unlike "Producer Responsibility" states (like Washington or Oregon), Alabama does not require electronics manufacturers to fund a statewide recycling system or register their brands in a specialized e-waste database. Instead, electronic waste is managed under the state's broader Solid Wastes and Recyclable Materials Management Act (SWRMMA) and Universal Waste Rules, overseen by the Alabama Department of Environmental Management (ADEM).

Does this apply to e-commerce & online sales

Since there is no formal EPR registration for electronics, e-commerce and online sellers are not required to register brands or pay per-unit recycling fees to the state of Alabama. However, if your business has a physical presence in Alabama (such as a warehouse or retail store) and you generate electronic waste, you must comply with ADEM Division 14 (Hazardous Waste) rules, which were updated with new requirements effective February 14, 2026.

Who is the “producer” under Alabama EPR?

Because there is no formal EPR framework, the legal concept of a "producer" in the context of recycling does not officially exist in Alabama. Responsibilities are instead placed on Generators (the businesses or entities discarding the waste).

• Retailers/Sellers: Have no mandatory take-back obligations for general electronics (except for specific lead-acid battery rules).

• Manufacturers: Are not legally required to provide or fund recycling for their products sold in Alabama.

Who must register for EPR packaging in Alabama

No registration is required. Alabama has not enacted a packaging EPR law. Producers and e-commerce sellers do not need to register with a Producer Responsibility Organization (PRO) like the Circular Action Alliance (CAA) for their sales in Alabama, nor is there a state registry for packaging materials.

Alabama EPR Packaging Registration Threshold

• Electronics: N/A (No registration exists).

• Packaging: N/A (No law enacted).

• Recycling Facilities: Only businesses that operate as a Materials Recovery Facility (MRF) or Recovered Materials Processing Facility (RMPF) in Alabama must register with ADEM. A major transition occurred on February 11, 2026, where all old "PRF" registrations expired and facilities were required to obtain new MRF or RMPF numbers.

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Packaging Covered (and Excluded)

• Covered Materials: None. Alabama does not regulate packaging via EPR fees.

• Lead-Acid Batteries: Alabama law strictly prohibits the disposal of lead-acid batteries in mixed municipal waste. Retailers must accept up to three used lead-acid batteries from customers for recycling if offered.

• Universal Waste: Certain electronics (mercury-containing equipment, batteries, lamps) are categorized as Universal Waste to allow for easier transport to recycling facilities rather than hazardous waste landfills.

Producer Responsibility Organization (PRO)

There is no designated PRO for Alabama. Most recycling efforts in the state are handled by local government grants funded by the Alabama Recycling Fund. Applications for these grants must be submitted via AEPACS by March 1st of each year.

EPR Registration in Alabama

• Manufacturer Registry: None for general electronics.

• ENDS Directory: Manufacturers of Electronic Nicotine Delivery Systems (ENDS) must be listed on the Alabama Department of Revenue’s approved directory.

• Facility Registration: Commercial recyclers must use the Alabama Environmental Permitting and Compliance System (AEPACS) to register.

Authorized Representative

Since there is no manufacturer registration for electronics or packaging, an Authorized Representative is not required for EPR compliance. However, for ENDS (vape) products, manufacturers must submit certifications via the My Alabama Taxes (MAT) portal.

What Data Must Be Reported

• Manufacturers/Sellers: No reporting required for general EEE.

• Registered Recycling Facilities: Must report recovery data annually via AEPACS on or before February 15th.

• Vape Manufacturers: Must provide SKU-level documentation and FDA marketing status for the state directory.

First Reporting Period & EPR Reporting Deadlines

• February 11, 2026: Deadline for existing recycling facilities to transition to new MRF/RMPF registration numbers.

• February 15, 2026: Annual deadline for registered recycling facilities to report recovery data.

• April 30, 2026: Annual deadline for ENDS (vape) manufacturers to renew their directory certification and pay the $500 renewal fee.

• October 1, 2026: Implementation of the new $0.10/ml vape excise tax on consumable vapor products (Act 2025-377).

Labels & Marketing Claims

• Battery Notice: Retailers of lead-acid batteries must post a 8.5 x 11 inch notice stating that landfill disposal is illegal.

• Vape Warnings: Retailers of ENDS products must display a specific sign (8.5 x 11 inches) warning that the use of some devices may increase exposure to toxic heavy metals such as lead, chromium, and nickel.

EPR Eco Fees & Eco-Modulation

• No Eco Fees: There are no state-mandated "eco-fees" at the point of sale for electronics in Alabama.

• Excise Tax: Note the upcoming October 1, 2026 excise tax for vapor products.

• Landfill Fees: A $1 per ton fee is collected at landfills to fund the state's recycling grant program.

Risks, Penalties & Common Mistakes

• Illegal Dumping: Discarding electronics in a dumpster is a violation of ADEM solid waste rules and can lead to significant fines.

• Unlisted Vape Products: Selling ENDS products not listed on the state directory carries daily penalties and potential seizure of inventory.

• Common Mistakes: Assuming Alabama follows "take-back" rules like other states; it remains a voluntary state for most electronics producers.

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FAQ

Do I need to pay a recycling fee for electronics sold in Alabama?

• No. Alabama has no point-of-sale recycling fee for general EEE.

Is e-waste banned from Alabama landfills?

• Businesses are legally required to manage hazardous electronics (like CRTs) through proper channels; lead-acid batteries are strictly prohibited for everyone.

What is the ENDS Directory?

• It is a mandatory list of approved vapor products. If your product isn't listed by April 30th, it cannot be sold in Alabama.

Where should I tell my Alabama customers to recycle?

• Refer them to the ADEM Recycling Program website or national retail take-back programs (e.g., Best Buy, Staples).

What is Alaska EPR EEE

As of March 2026, Alaska is in a significant transition period regarding electronic waste. Historically, the state had no mandatory Extended Producer Responsibility (EPR) law. However, SB 61 (Electronic Product Stewardship Program) was introduced and debated during the 2025–2026 legislative session. While the full stewardship obligations (manufacturer-funded recycling) are slated for later implementation (registrations starting 2028), the state has moved to treat e-waste as Universal Waste under new Hazardous Waste Regulations (18 AAC 62) effective June 1, 2025. This program is overseen by the Alaska Department of Environmental Conservation (DEC).

Does this apply to e-commerce & online sales

Yes, the emerging stewardship framework applies to any manufacturer whose products are "offered for sale" in Alaska, including through internet sales and distance retailers. Under the new state-led Hazardous Waste Program (seeking full EPA authorization in mid-2026), online sellers must ensure their products meet labeling and "Universal Waste" disposal guidelines if they have a physical presence or significant nexus in the state.

Who is the “producer” under Alaska EPR?

Under the stewardship framework being established in 2026, a "manufacturer" (producer) includes:

1. Brand Owners: Any person who manufactures a covered electronic device under its own brand.

2. Licensees: Any person who sells a device under its own brand produced by others.

3. Importers: For foreign brands with no U.S. presence, the first importer into the U.S. who sells the product in Alaska is considered the producer.

Who must register for EPR packaging in Alaska

No registration is required yet. Alaska does not currently have an active packaging EPR law (like the "Circular Action Alliance" requirements in other states). While the DEC is streamlining regulations under AO 360 in 2026, the focus remains on hazardous waste and electronic product stewardship rather than general packaging materials.

Alaska EPR Packaging Registration Threshold

• Electronics Stewardship: Under the proposed SB 61 timeline, initial brand registrations will not be required until June 2028.

• Hazardous Waste: There is no "unit threshold" for compliance with Universal Waste rules; any business generating regulated e-waste must comply with storage and transport standards as of June 1, 2025.

• Small Quantity Generators (SQG): Businesses generating less than 100 kg of hazardous waste per month have simplified requirements but must still avoid landfilling prohibited items.

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Packaging Covered (and Excluded)

The current regulatory focus in Alaska is on Covered Electronic Devices (CEDs):

1. Covered EEE: Computers, monitors, laptops, and televisions (typically those with screens >4 inches).

2. Lead-Acid Batteries: Disposal in municipal solid waste is strictly prohibited.

3. Exclusions:

   • Motor vehicle components.

   • Large-scale industrial or medical equipment.

   • Household appliances (white goods) that do not contain a regulated display screen.

Producer Responsibility Organization (PRO)

Alaska is establishing an Electronics Recycling Advisory Council to oversee the transition to a PRO-led model. By 2027-2028, manufacturers will be expected to join a PRO to manage the unique logistical challenges of e-waste collection in Alaska’s rural and remote areas.

EPR Registration in Alaska

• Manufacturer Registry: Not currently active for 2026 sales.

• Hazardous Waste ID: Businesses in Alaska can now apply for state-specific EPA ID numbers through the DEC’s new hazardous waste portal as part of the 2026 program authorization.

Authorized Representative

For the upcoming stewardship program, foreign manufacturers will be required to appoint a local Authorized Representative to manage their "Manufacturer E-Scrap Program Plan." In the interim (2026), importers are responsible for ensuring that disposal information is available to consumers.

What Data Must Be Reported

Under the new 18 AAC 62 regulations (effective June 2025):

• Annual Reports: Large quantity handlers of Universal Waste must report the types and amounts of e-waste managed.

• Stewardship Data: Future requirements (post-2027) will include the weight of all electronics sold in the state by category.

First Reporting Period & EPR Reporting Deadlines

• January 1, 2026: Transition to new state-level hazardous waste enforcement begins.

• March 31, 2028: First deadline for manufacturers to submit proposed e-scrap program plans.

• June 30, 2028: Deadline for initial manufacturer registration under the new stewardship act.

Labels & Marketing Claims

• Branding: All covered electronics sold in Alaska must be permanently labeled with the manufacturer’s brand.

• Disposal Notices: Manufacturers are encouraged to provide "Do Not Landfill" notices, as Alaska’s DEC is increasing enforcement on illegal e-waste disposal in 2026.

EPR Eco Fees & Eco-Modulation

• No Eco Fees: Alaska does not currently charge a point-of-sale "Advanced Recycling Fee."

• Program Administration Fees: Starting in the 2028 cycle, manufacturers will pay an annual fee to the DEC to fund the oversight of the stewardship program.

Risks, Penalties & Common Mistakes

• Littering & Illegal Disposal: Penalties for illegal e-waste disposal are being posted more aggressively at state parks and public entrances in 2026.

• RCRA Compliance: Since Alaska is transitioning from Federal (EPA) to State (DEC) oversight in 2026, failing to update your waste manifest procedures to state standards is a common risk.

• Common Mistakes: Assuming that Alaska's remote nature exempts you from "Universal Waste" rules—the DEC is specifically targeting rural "backhaul" programs for compliance.

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FAQ

• No, there is no manufacturer registration code required for sales this year.

• Yes, they are managed under the Universal Waste rules; they must be separated from general trash to prevent landfill fires.

• While bills have been introduced, Alaska has not yet enacted a formal "Right to Repair" law as of early 2026.

• The DEC maintains a list of permitted hazardous waste handlers, but the official "Compliant Manufacturer" list for stewardship is not expected until 2028.

What is Arizona EPR EEE

Extended Producer Responsibility (EPR) for electronics in Arizona is governed by the Arizona Electronic Device Recycling Act (SB 1419). Effective January 1, 2026, this law mandates that manufacturers of "Covered Electronic Devices" (CEDs) take responsibility for the collection, transportation, and recycling of their products from households and small entities. The program is designed to shift the financial burden of e-waste management from municipalities to the producers. The Arizona Department of Environmental Quality (ADEQ) oversees the program and maintains the registry of compliant brands.

Does this apply to e-commerce & online sales

Yes. The law applies to any manufacturer or retailer that sells or offers for sale covered electronic devices "in or for delivery in" Arizona. This explicitly includes internet sales, catalog transactions, and other forms of remote commerce. If a foreign or out-of-state company sells a CED to an Arizona resident via a website, they are legally responsible for registration, labeling, and establishing a take-back plan.

Who is the “producer” under Arizona EPR?

Under the 2026 Arizona statutes, the "manufacturer" (producer) is defined as:

1. Brand Owners: Any person who manufactures a covered electronic device under its own brand or label.

2. Licensees: Any person who sells a device under its own brand produced by others.

3. Importers: If the brand owner has no physical presence in the United States, the first importer into the U.S. who sells the product in Arizona assumes the legal responsibilities.

Who must register for EPR packaging in Arizona

All manufacturers of covered electronic devices must register with the ADEQ.

1. Electronics Registration: Mandatory annually starting January 1, 2026.

2. Packaging: Arizona does not currently have a mandatory statewide packaging EPR program. However, manufacturers must ensure their electronic hardware meets all specific Arizona registration requirements to remain legal for sale.

Arizona EPR Packaging Registration Threshold

Arizona's electronics law requires registration from the first unit sold to a household.

1. New Market Entrants: Any manufacturer that begins selling CEDs in Arizona after January 1, 2026, and has not filed a registration must submit one to the ADEQ within 10 days of their first sale.

2. Annual Fee: Manufacturers must pay an annual registration fee determined by the ADEQ (typically deposited into the Solid Waste Fee Fund).

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Packaging Covered (and Excluded)

The Arizona law focuses on specific hardware categories:

1. Covered EEE (CEDs): Desktop computers, laptop/portable computers, computer monitors, and televisions with a screen greater than 4 inches diagonally.

2. Exclusions:

• Motor vehicle components and large-scale industrial equipment.

• Telephones (smartphones are currently excluded).

• Electronic cigarettes (unless they meet specific battery-embedded criteria under separate rules).

Producer Responsibility Organization (PRO)

Arizona allows manufacturers to satisfy the law through an Individual Plan or a Group Plan. Most manufacturers participate in a collective program to meet the "convenient service" requirements, which include providing collection sites or events in every county and in any city with a population over 50,000.

EPR Registration in Arizona

1. myDEQ Portal: Manufacturers must register through the ADEQ’s digital portal, myDEQ.

2. Annual Renewal: Registration must be renewed on or before January 1st each year.

3. Plan Submission: Manufacturers must submit a plan describing their statewide program for collecting, transporting, and recycling devices from covered entities free of charge.

Authorized Representative

Foreign manufacturers with no U.S. presence must appoint an Authorized Representative or rely on their Importer of Record. This representative is responsible for filing the annual registration and ensuring the manufacturer’s collection plan meets the "environmentally sound management practices" required by the ADEQ.

What Data Must Be Reported

Manufacturers must report the following annually:

1. A list of all brand names sold in Arizona.

2. The total weight of covered electronic devices collected and recycled in the previous year.

3. Documentation of publicity and promotion efforts used to inform consumers about recycling opportunities.

First Reporting Period & EPR Reporting Deadlines

1. Initial Registration: Due January 1, 2026.

2. Annual Fee/Renewal: Due January 1st of each subsequent year.

3. New Entrants: Registration is due within 10 days of the first sale after the program start date.

Labels & Marketing Claims

As of January 1, 2026, a manufacturer or retailer may not sell a covered electronic device in Arizona unless it is labeled with a brand that is permanently affixed and readily visible. The use of deceptive or misleading claims regarding a product's recyclability is strictly prohibited under 2026 consumer protection enhancements.

EPR Eco Fees & Eco-Modulation

Arizona utilizes an Administrative Fee system rather than a per-unit eco-fee.

1. Registration Fee: Paid annually to the ADEQ to cover program oversight.

2. Collection Costs: Manufacturers must provide recycling free of charge to consumers, internalizing the costs of transport and processing into their business model.

Risks, Penalties & Common Mistakes

1. Civil Penalties: Violations can result in penalties of up to $2,500 per day, with a maximum of $100,000 per violation.

2. Sales Prohibition: Retailers are prohibited from selling brands that are not listed on the ADEQ registry.

3. Common Mistakes: Failing to register new brands within the 10-day window and neglecting the requirement for "convenient" collection sites in all counties.

What E-Commerce Sellers Should Do Now

1. Register on myDEQ: Ensure your company is registered before the January 1st annual deadline.

2. Verify Branding: Confirm all electronics shipped to Arizona have permanent, visible manufacturer labels.

3. Review Collection Plan: If you are a brand owner, ensure your recycling plan provides the mandatory "free of charge" service for Arizona residents.

4. Audit Retail Partners: Ensure your brand appears on the ADEQ compliance list to avoid your products being pulled from digital marketplaces.

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FAQ

• Registration and free consumer take-back are mandatory for all manufacturers of covered electronics sold in Arizona.

• Non-U.S. companies must comply through a U.S.-based Authorized Representative or their first importer.

• There is no volume exemption; registration is required from the first unit sold, though the ADEQ may adjust fees by rule.

• Permanent manufacturer labels are required; unbranded products cannot be legally sold in the state.

• Online platforms are restricted from hosting brands that are not registered with the ADEQ as of January 2026.

What is Arkansas EPR EEE

As of March 2026, Arkansas remains a non-EPR state for electronics. Unlike states with mandatory "Producer Responsibility" laws (such as California or Minnesota), Arkansas does not require manufacturers to fund a statewide collection system or meet specific recycling targets. Instead, the state follows the Arkansas Computer and Electronic Solid Waste Management Act (Act 1410 of 2001), which focuses on state agency electronics management and voluntary recycling grants. The Arkansas Department of Energy and Environment (E&E), specifically the Division of Environmental Quality (DEQ), oversees these voluntary programs.

Does this apply to e-commerce & online sales

Since there is no mandatory EPR registration or point-of-sale recycling fee for general electronics in Arkansas, e-commerce and online sellers are not required to register brands or collect "eco-fees" from Arkansas customers. However, online retailers with a physical presence (Nexus) in the state must still comply with Universal Waste Rules regarding the handling and disposal of hazardous e-waste (like CRTs or batteries) from their own operations.

Who is the “producer” under Arkansas EPR?

Because Arkansas lacks a formal EPR framework, there is no legal "Producer" definition for electronics recycling.

• Manufacturers: Have no legal mandate to provide "take-back" programs.

• State Agencies: Are the primary regulated entities under Act 1410, required to have plans for the "demanufacturing" and secure data destruction of their surplus electronics.

Who must register for EPR packaging in Arkansas

No registration is required. Arkansas has not enacted a packaging EPR law as of early 2026. Producers selling into Arkansas do not need to register with a Producer Responsibility Organization (PRO) like the Circular Action Alliance (CAA) for this specific state.

Arkansas EPR Packaging Registration Threshold

• Electronics: N/A (No registration exists).

• Packaging: N/A (No law enacted).

• Grants: Only local governments and solid waste management districts that apply for Computer and Electronic Equipment Recycling Grants must go through a formal state application process.

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Packaging Covered (and Excluded)

• Covered Materials: None. Arkansas does not regulate packaging via EPR.

• Regulated E-Waste: While not an EPR law, Arkansas Universal Waste rules encourage the recycling of:

  • Desktop and laptop computers.

  • Computer monitors and televisions (especially those containing Cathode Ray Tubes).

  • Printers, fax machines, and cell phones.

• Lead-Acid Batteries: Disposal in municipal landfills is prohibited; they must be recycled through a lead-acid battery retailer or a secondary lead smelter.

Producer Responsibility Organization (PRO)

There is no designated PRO for Arkansas. E-waste recycling is primarily managed by Regional Solid Waste Management Districts using state-funded grants and private IT Asset Disposition (ITAD) vendors.

EPR Registration in Arkansas

• Manufacturer Registry: None.

• E-Waste Collection Centers: Local collection sites and brokers may voluntarily register with the DEQ to be listed on the state's public recycling map.

Authorized Representative

An Authorized Representative is not required for EPR compliance. However, for e-commerce sellers, a Registered Agent is still recommended for standard business compliance and to handle any inquiries regarding Universal Waste violations.

What Data Must Be Reported

• Manufacturers/Sellers: No reporting is required for sales or recycling volumes.

• Recycling Grant Recipients: Must submit reports to the DEQ detailing how grant funds were used and the total weight of electronic waste diverted from landfills.

First Reporting Period & EPR Reporting Deadlines

• Ongoing: Grant applications for the Computer and Electronic Equipment Recycling Fund are typically reviewed on an annual cycle.

• 2026 Focus: The DEQ is currently updating its "State of Recycling in Arkansas" report, which compiles data from voluntary recycling programs.

Labels & Marketing Claims

• Manufacturer Labeling: While not a state mandate, products must follow federal FTC "Green Guides" if making recyclability claims.

• Data Security: Arkansas Act 1410 places heavy emphasis on data destruction. Manufacturers and recyclers are encouraged to follow NIST 800-88 standards for data sanitization.

EPR Eco Fees & Eco-Modulation

• No State Fee: Arkansas does not charge an "Advanced Recycling Fee" at checkout.

• Grant Funding: The state's electronics recycling programs are funded by a portion of the solid waste disposal fees collected at landfills, not by direct producer fees.

Risks, Penalties & Common Mistakes

• Data Breaches: Under Arkansas Code § 25-34-103, improper disposal of devices containing sensitive data can lead to legal liability.

• Hazardous Waste Violations: Discarding large quantities of CRTs (older monitors) or lithium-ion batteries in a commercial dumpster is a violation of federal and state hazardous waste laws.

• Common Mistakes: Assuming that a "voluntary" state means no rules—Arkansas is active in prosecuting illegal dumping and hazardous waste mismanagement.

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FAQ

Do I need an EPR code for Arkansas?

• No. There is no manufacturer code or EPR registration number for Arkansas.

Is there a landfill ban on electronics?

• There is no statewide ban for households, but many Regional Solid Waste Management Districts have their own local bans and provide specific drop-off centers instead.

Do I need to report sales data?

• No, Arkansas does not track manufacturer sales for electronics recycling purposes.

Where should I tell my Arkansas customers to go?

• Direct them to the ADEQ E-waste Collection Centers directory.

What is California EPR EEE

Extended Producer Responsibility (EPR) for Electrical and Electronic Equipment (EEE) in California is a regulatory framework designed to manage the lifecycle of electronics. It is primarily governed by the Electronic Waste Recycling Act of 2003 and significantly expanded by Senate Bill (SB) 1215. As of January 1, 2026, California has introduced a new Covered Battery-Embedded (CBE) Waste Recycling Fee, which extends responsibility to a vast range of portable electronics with non-removable batteries. The California Department of Resources Recycling and Recovery (CalRecycle) oversees the program, while the California Department of Tax and Fee Administration (CDTFA) handles the collection of fees.

Does this apply to e-commerce & online sales

Yes. The law applies to all retail sales of covered electronic devices and battery-embedded products to consumers in California, regardless of the seller's location. This includes cross-border e-commerce sellers, distance sellers, and marketplace facilitators. If you sell a covered product through an online platform to a California address, the responsibility to ensure the fee is collected and remitted falls on the retailer (or the marketplace facilitator acting as the retailer).

Who is the “producer” under California EPR?

In the context of California’s EEE and E-waste laws, the responsible entities include:

1. Manufacturers: Entities that manufacture and sell covered electronic products under their own brand.

2. Brand Owners: Entities that own the brand or license for a covered product sold in California.

3. Importers: Companies that import covered products into the United States for sale in California.

4. Retailers/Online Sellers: Any entity engaged in the retail sale of covered electronics, including foreign companies selling directly to California residents.

Who must register for EPR packaging in California

Every retailer (including online sellers) "engaged in business in California" who sells covered electronic devices must register for a Covered Electronic Waste (CEW) Recycling Fee account and/or a Covered Battery-Embedded (CBE) account with the CDTFA. Manufacturers also have specific registration and notification obligations to CalRecycle to identify their covered products.

California EPR Packaging Registration Threshold

California does not have a "de minimis" or minimum sales threshold for E-waste compliance. The obligation to register, collect the fee, and report data begins with the first sale of a covered electronic device to a customer in California. Foreign sellers are not exempt based on volume or turnover.

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Packaging Covered (and Excluded)

While this guide focuses on EEE, it is important to note that SB 54 (Plastic Pollution Prevention and Packaging Producer Responsibility Act) regulates the packaging of these electronics.

1. Covered EEE: Includes "Covered Electronic Devices" (CEDs) like video displays (>4 inches) and "Covered Battery-Embedded" (CBE) products (e.g., smartphones, tablets, smartwatches, power tools).

2. Exclusions:

• Certain medical devices (Class II and III).

• Energy storage systems (e.g., home battery backups).

• Electronic nicotine delivery systems (e-cigarettes).

• Devices where the battery is easily removable by the user with common household tools.

Producer Responsibility Organization (PRO)

Unlike European models with private PROs, California’s E-waste system is a state-run program. Retailers remit fees directly to the CDTFA, and these funds are used by the state to pay for authorized collectors and recyclers. For the packaging aspect (SB 54), producers must join the Circular Action Alliance (CAA), which serves as the designated PRO for packaging materials.

EPR Registration in California

1. Account Registration: Create an account via the CDTFA online portal for the relevant fee programs (CEW and CBE).

2. Manufacturer Notification: On or before July 1st annually, manufacturers must notify CalRecycle and all their retailers of which products are "covered" or "exempt."

3. Nexus Determination: Out-of-state sellers must determine their "nexus" status, though most e-commerce activity into California now triggers mandatory collection.

Authorized Representative

Foreign companies (manufacturers) are encouraged to appoint a compliance partner or local representative to manage the annual CalRecycle notifications and reporting. For the CDTFA fee remittance, foreign retailers can register directly but often use tax automation providers to handle the calculations and filings.

What Data Must Be Reported

Obligated entities must report:

• Unit Sales: Total number of covered products sold in or into California.

• Product Categories: Specific identification of the device type (e.g., screen size or battery-embedded status).

• Battery Chemistry: For CBE products, information on the battery's chemical composition must be available.

• Retailer Lists: Manufacturers must report which retailers they have notified.

First Reporting Period & EPR Reporting Deadlines

1. Fee Collection: Mandatory collection of the CBE fee begins January 1, 2026.

2. Remittance Deadlines: Fees must typically be filed and paid to the CDTFA on a quarterly basis, due on or before the last day of the month following the reporting period (e.g., April 30, 2026, for Q1).

3. Annual Manufacturer Report: Due to CalRecycle on or before July 1st of each year.

Labels & Marketing Claims

Covered electronic products must be labeled with the manufacturer’s name or brand. Additionally, CBE products must either be labeled with the battery chemistry or have this information clearly accessible on the manufacturer's website. Receipts provided to consumers must separately identify the recycling fee as a distinct line item.

EPR Eco Fees & Eco-Modulation

Fees are set by CalRecycle and are generally flat rates or percentages:

• CED Fees: Based on screen size categories.

• CBE Fees: Effective January 1, 2026, a fee of 1.5% (capped at $15) is applied to the retail sales price of covered products.

  These fees are adjusted annually to ensure the program's costs for collection and recycling are covered.

Risks, Penalties & Common Mistakes

• Fines: Failure to comply can result in administrative civil penalties of up to $2,500 per violation or $5,000 for intentional violations.

• Market Access: CalRecycle may ban the sale of products from manufacturers who fail to submit required notifications.

• Common Mistakes: Failing to list the fee as a separate line item on the invoice and neglecting to register for the new CBE fee specifically, assuming it is covered by standard sales tax.

What E-Commerce Sellers Should Do Now

1. Audit Product Portfolio: Identify which electronic products contain non-removable batteries.

2. Register with CDTFA: Ensure you have a CBE and/or CEW recycling fee account active before January 1, 2026.

3. Update Invoicing Systems: Configure your checkout process to calculate and display the fee as a separate line item.

4. Notify Retailers: If you are a manufacturer, send your mandatory product identification notice by July 1st.

5. Monitor SB 54: Ensure your product packaging is also registered through the Circular Action Alliance.

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FAQ

• Is the California CBE fee mandatory for sellers outside the USA?

  Yes, any seller shipping covered electronics to a California consumer is responsible for collecting and remitting the fee.

• What happens if a marketplace like Amazon collects the fee?

  Marketplace facilitators are generally responsible for the collection; however, sellers should verify their specific contract terms to ensure compliance is met.

• Is there a minimum sales threshold for E-waste fees?

  No, there is a zero-threshold policy; the fee applies to the very first sale.

• Do I need to put a label on the battery?

  The product itself must identify the battery chemistry or point to a website where the information is available.

• Does this fee replace the packaging EPR fee (SB 54)?

  No, these are separate obligations. One covers the electronic product (EEE), and the other covers the packaging it comes in.

What is Colorado EPR EEE

Extended Producer Responsibility for Electrical and Electronic Equipment in Colorado is primarily managed through the Electronic Device Recycling Protection Act. This law prohibits consumers from disposing of electronic devices in landfills and requires manufacturers of specific equipment to establish or participate in recycling programs. As of 2026, the state is also integrating these requirements with the broader Circular Economy Development Center initiatives to enhance recovery rates for precious metals and hazardous components. The Colorado Department of Public Health and Environment (CDPHE) is the lead regulatory agency.

Does this apply to e-commerce & online sales

Yes. The act applies to any "manufacturer" or "retailer" that sells or offers for sale covered electronic devices to individuals or small businesses in Colorado. This includes cross-border e-commerce sellers and online retailers. If a foreign entity sells a covered device via a website to a Colorado resident, they are responsible for ensuring that the brand is registered and that the consumer has access to required recycling information.

Who is the “producer” under Colorado EPR?

Under Colorado law, the "manufacturer" is the primary obligated party, defined as:

1. Brand Owners: Any person who manufactures a covered electronic device under its own brand or label.

2. Licensees: Any person who sells a covered electronic device under its own brand produced by others.

3. Importers: Any person who imports a covered electronic device manufactured by a person without a presence in the United States.

Who must register for EPR packaging in Colorado

Manufacturers of covered electronic devices must register annually with the CDPHE. Retailers (including online sellers) are prohibited from selling a covered electronic device unless the manufacturer is listed on the CDPHE website as being in compliance. While retailers do not always have to register as "producers," they must maintain records proving they only sell compliant brands.

Colorado EPR Packaging Registration Threshold

Colorado does not provide a specific "small-seller" de minimis exemption based on revenue for electronics. If a manufacturer’s brand is sold in the state, registration is required. However, for the packaging-specific EPR law (HB22-1355), there is an exemption for producers with less than $5 million in realized gross total revenue in the US or those who place less than 1 ton of packaging on the market.

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Packaging Covered (and Excluded)

The E-waste law covers "Covered Electronic Devices" (CEDs), while the packaging is covered by the separate Producer Responsibility Program for Recycling.

1. Covered EEE: Includes computers, monitors, laptops, tablets, printers, and video display devices (>4 inches).

2. Exclusions:

• Motor vehicle components.

• Large appliances (white goods).

• Telephones (except for tablets with cellular capability).

• Industrial or medical equipment that contains a display but is not a standalone consumer electronic.

Producer Responsibility Organization (PRO)

Colorado utilizes a "Market Share" or "Return Share" model. Manufacturers must either implement an individual recycling program or, more commonly, join a collective program. For the packaging aspect, the Circular Action Alliance (CAA) has been designated as the sole PRO to manage the statewide recycling system for all packaging materials.

EPR Registration in Colorado

1. Manufacturer Registration: Submit an annual registration form and a $500 fee to the CDPHE.

2. Recycling Plan: Submit a plan detailing how the manufacturer will provide free and convenient recycling to Colorado residents.

3. Retailer Verification: Online sellers must check the CDPHE Compliant Manufacturer List before listing electronic products for sale.

Authorized Representative

Foreign manufacturers who do not have a physical presence in the United States must appoint an Authorized Representative or an importer of record to assume the legal responsibilities for registration, reporting, and plan implementation within the state of Colorado.

What Data Must Be Reported

Obligated manufacturers must report:

• The weight of all covered electronic devices sold in Colorado during the previous calendar year.

• The weight of all electronic waste collected and recycled by the manufacturer’s program.

• A list of all brand names under which the manufacturer sells devices.

First Reporting Period & EPR Reporting Deadlines

1. Annual Registration: Due by January 30th of each year.

2. Annual Progress Report: Manufacturers must submit a report detailing the previous year's collection amounts by January 30th.

3. Packaging EPR (HB22-1355): Initial data collection for packaging began in 2024-2025, with fee payments scaling up significantly by 2026.

Labels & Marketing Claims

Every covered electronic device sold in Colorado must be labeled with the manufacturer’s brand, and this brand must be permanently affixed and readily visible. Additionally, manufacturers and retailers must provide recycling information to consumers at the time of sale, which can be done via a website link on the checkout page or an insert in the packaging.

EPR Eco Fees & Eco-Modulation

For E-waste, manufacturers pay an annual $500 registration fee plus the operational costs of their recycling programs. For the packaging EPR (SB 54/HB 1355), fees are eco-modulated based on the recyclability of the materials, the use of recycled content, and the presence of "toxic substances" like PFAS.

Risks, Penalties & Common Mistakes

• Fines: Violations can result in civil penalties of up to $10,000 per day.

• Stop-Sale Orders: Retailers selling non-compliant brands can be ordered to immediately cease sales of those products.

• Common Mistakes: Foreign sellers often fail to check if their manufacturer is registered with the CDPHE, leading to liability for the retailer.

What E-Commerce Sellers Should Do Now

1. Verify Brands: Cross-reference your electronic inventory against the CDPHE Compliant Manufacturer List.

2. Appoint an AR: If you are a foreign brand owner, appoint a local representative to handle the January 30th registration.

3. Update Consumer Info: Ensure your website provides a clear link to electronics recycling locations in Colorado for your customers.

4. Register for Packaging: If your US revenue exceeds $5M, ensure you are registered with the Circular Action Alliance for your boxes and mailers.

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FAQ

• Registration and compliance are mandatory for any manufacturer or retailer whose covered products enter the Colorado market.

• Non-US companies must comply through an importer or a designated Authorized Representative to fulfill registration and recycling obligations.

• While there is a $5 million threshold for the packaging EPR program, the electronics (E-waste) law has no such minimum for brand registration.

• All devices must be permanently labeled with the brand name, and recycling information must be provided to the consumer at the point of sale.

• Online marketplaces are increasingly required to ensure that the electronic brands sold on their platforms are compliant with the CDPHE registry.

What is Connecticut EPR EEE

Connecticut operates one of the oldest and most established mandatory Extended Producer Responsibility (EPR) programs for electronics in the U.S., governed by CGS §§ 22a-629 through 22a-640. Unlike voluntary states, Connecticut requires manufacturers to finance the transportation and recycling of "Covered Electronic Devices" (CEDs) collected by municipalities. The Department of Energy and Environmental Protection (DEEP) oversees the program, ensuring manufacturers—not taxpayers—pay for the end-of-life management of their products.

Does this apply to e-commerce & online sales

Yes. The law applies to any manufacturer that "sells or offers for sale" a CED in Connecticut. This includes all online, catalog, and telephone sales.

• Sales Ban: Retailers (including online marketplaces) are strictly prohibited from selling brands that are not on the DEEP Compliant Manufacturer List.

• Customer Info: You must provide e-waste recycling information to your customers at the time of sale (often via a link to the DEEP website or a toll-free number).

Who is the “producer” under Connecticut EPR?

A "producer" (manufacturer) is defined as any person who:

1. Brand Owners: Manufactures a CED under its own brand or label.

2. Licensees: Sells a CED under its own brand produced by others.

3. Importers: If the brand owner has no physical presence in the U.S., the first importer into the country is legally responsible for the product's end-of-life costs in Connecticut.

Who must register for EPR packaging in Connecticut

• Electronics: Mandatory registration for all manufacturers of computers, printers, monitors, and TVs.

• Packaging: As of March 2026, Connecticut does not have a mandatory packaging EPR law. While a formal study on the viability of packaging EPR was proposed in 2025, it has not yet transitioned into an active registration requirement for producers.

• Batteries: Under Public Act 25-34 (passed in 2025), a new Battery EPR program is active. Producers must submit their stewardship plans to DEEP by July 1, 2026, with full implementation and sales bans on non-compliant batteries starting in 2027.

Connecticut EPR Registration Threshold

• Electronics: 0-unit threshold. If you sell even one branded CED in the state, you must register.

• Registration Fees: Manufacturers must pay an annual registration renewal fee (based on market share or a flat fee) to the DEEP.

• Orphan Share: Manufacturers are also responsible for a pro-rata share of "orphan devices" (branded items from companies no longer in business).

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Packaging Covered (and Excluded)

The Connecticut program is specific to Covered Electronic Devices (CEDs):

1. Covered: Desktop computers, laptops, monitors (CRTs and flat panels), printers, and televisions.

2. Excluded:

• Motor vehicle components.

• Video game consoles (if not functioning as a computer).

• Handheld devices (PDAs/Smartphones) are generally excluded from the CED definition but may fall under the new 2026 Battery EPR rules.

Producer Responsibility Organization (PRO)

Unlike other states, Connecticut's electronics program does not use a single PRO.

• Instead, it uses a Covered Electronic Recycler (CER) model.

• DEEP approves specific recyclers who then bill manufacturers directly for the actual weight of their branded products (plus orphan share) collected at municipal sites.

• However, for the new Battery EPR (2026), producers must join an approved Battery Stewardship Organization.

EPR Registration in Connecticut

• Annual Renewal: Manufacturers must renew their registration with DEEP annually.

• Recycler Renewal: For 2026, approved recyclers (CERs) must submit their renewal applications between January 7 and March 9, 2026.

• Do Not Sell List: If a manufacturer fails to register or pay its recycling invoices, it is placed on a public "Do Not Sell" list, making its products illegal for retail in CT.

Authorized Representative

Manufacturers may appoint an Authorized Representative to handle registrations and billing arrangements with CERs. For foreign companies, the first importer usually acts as the point of contact for financial and legal liability.

What Data Must Be Reported

• Recyclers (CERs): Report the total weight of devices collected, sorted by brand.

• Manufacturers: Must report their annual sales data to DEEP (or use market share data provided by the state) to determine their financial obligation for the upcoming year.

First Reporting Period & EPR Reporting Deadlines

• March 9, 2026: Deadline for CER (Recycler) renewal applications.

• July 1, 2026: Deadline for battery producers to submit their Battery Stewardship Plans to DEEP.

• Quarterly: Manufacturers are typically billed quarterly by CERs for the weight of materials processed.

Labels & Marketing Claims

• Permanent Labels: All CEDs sold in CT must have a visible, permanent label identifying the manufacturer.

• Battery Labeling: Under the new 2025/2026 rules, specific labeling for lithium and medium-format batteries will be required by 2029, but preparation for these labels starts in the 2026 planning phase.

EPR Eco Fees & Eco-Modulation

• Internalized Costs: There is no fee charged to consumers at the register. Manufacturers pay the costs of the program "behind the scenes."

• Recycling Rates: Recyclers bill manufacturers at a rate per pound that is approved by the DEEP Commissioner.

Risks, Penalties & Common Mistakes

• Sales Prohibition: The most significant risk is being added to the "Do Not Sell" list, which cuts off all legal retail channels in the state.

• Disposal Ban: It has been illegal to dispose of CEDs in CT landfills since 2011; businesses caught dumping can face heavy environmental fines.

• Common Mistakes: Forgetting that printers are covered in CT (many other states exclude them).

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FAQ

Do I need to register my brand if I only sell on Amazon?

• Yes. If the product is delivered to a Connecticut address, the brand must be registered with DEEP.

Are vapes covered under Connecticut EPR?

• In March 2026, the legislature is currently studying a specific EPR bill (SB 147) to add vapes and solar panels to the program.

What is the "Orphan Share"?

• It is the cost of recycling devices from companies that no longer exist. This cost is split among all registered manufacturers based on their market share.

Is there a Right to Repair in Connecticut?

• Yes, Connecticut is one of the states that has enacted Right to Repair policies (as of early 2026), specifically for certain electronic classes.

What is Delaware EPR EEE

As of March 2026, Delaware remains a non-EPR state for electronics. There is no mandatory "Extended Producer Responsibility" law that requires manufacturers to fund a statewide recycling system or meet specific recovery targets. Instead, the state relies on the Delaware Solid Waste Authority (DSWA) and its network of recycling centers to manage e-waste. While producers aren't forced to pay for a collective system, Delaware law prohibits most electronic waste from entering landfills, placing the responsibility for proper disposal on the end-user and business generators.

Does this apply to e-commerce & online sales

Because there is no formal EPR registry or per-unit fee, e-commerce and online sellers are not required to register their brands or collect "recycling taxes" from Delaware customers at checkout. Your primary obligation as a seller is to ensure products are labeled correctly (if battery rules apply) and to comply with federal standards for hazardous material disclosures.

Who is the “producer” under Delaware EPR?

Since no formal EPR framework exists, there is no legal "Producer" definition for electronics recycling in Delaware.

• Manufacturers: Have no legal mandate to finance end-of-life recovery.

• Businesses (Generators): Are the regulated parties. Businesses in Delaware are legally required to recycle items like computers, monitors, and servers rather than disposing of them in general trash.

Who must register for EPR packaging in Delaware

No registration is required. As of March 2026, Delaware has not enacted a packaging EPR law. Producers do not need to register with a PRO (like the Circular Action Alliance) for Delaware, although you likely already do so for nearby states like Maryland or New Jersey which have active or pending requirements.

Delaware EPR Packaging Registration Threshold

• Electronics: N/A (No registration exists).

• Packaging: N/A (No law enacted).

• Hazardous Waste: Businesses that accumulate 5,000 kg (approx. 11,000 lbs) or more of universal waste (including batteries and mercury-containing equipment) must notify the DNREC and receive an EPA ID Number.

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Packaging Covered (and Excluded)

• Covered Materials: None. Delaware does not regulate packaging via EPR fees.

• Prohibited Items (Landfill Ban): Under Delaware's environmental guidelines, the following must be diverted from landfills:

  • Computers, laptops, and tablets.

  • Monitors (both flat-screen and older CRTs).

  • Printers, keyboards, and mice.

• Lead-Acid Batteries: Strictly prohibited from municipal waste; must be returned to a retailer or specialized recycler.

Producer Responsibility Organization (PRO)

There is no designated PRO for Delaware. E-waste recycling is managed by the Delaware Solid Waste Authority (DSWA) through its collection events and permanent drop-off sites.

EPR Registration in Delaware

• Manufacturer Registry: None.

• Business Compliance: Businesses should maintain a Certificate of Destruction or a bill of lading from an ITAD (IT Asset Disposition) provider to prove compliance with landfill bans and data security laws.

Authorized Representative

An Authorized Representative is not required for EPR registration because the registry does not exist. However, for e-commerce companies, having a Registered Agent in Delaware is a standard requirement for general business operations.

What Data Must Be Reported

• Manufacturers/Sellers: No reporting required.

• Large Quantity Handlers: Businesses that accumulate large amounts of universal waste (e.g., batteries) must track shipments on a manifest and keep records for at least 3 years.

First Reporting Period & EPR Reporting Deadlines

• No EPR Deadlines: There are no annual producer reports due for electronics or packaging in 2026.

• Federal Transition: Note that in 2026, the EPA is moving toward a paper manifest sunset for hazardous waste, meaning Delaware businesses will need to use the e-Manifest system for any regulated e-waste shipments.

Labels & Marketing Claims

• Manufacturer Labeling: Products must be labeled with the manufacturer's brand, though this is a market standard rather than a specific Delaware EPR requirement.

• Data Privacy: Delaware law emphasizes that businesses are responsible for secure data destruction on all retired devices.

EPR Eco Fees & Eco-Modulation

• No State Fee: Delaware does not charge an "Advanced Recycling Fee" at the point of sale.

• Free Resident Drop-off: The DSWA offers free electronics recycling for residents (not businesses) at its recycling centers, funded through general tipping fees at landfills.

Risks, Penalties & Common Mistakes

• Landfill Fines: Disposing of electronics in a commercial dumpster can lead to significant environmental penalties from the DNREC.

• Data Breaches: Improperly handling old servers or laptops is a major liability; a single data breach from an unrecycled device can lead to civil lawsuits.

• Common Mistakes: Assuming that because there is no "producer fee," there are no rules—Delaware is strict about keeping lead and mercury out of its soil and water.

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FAQ

Is there a code I need for Delaware e-waste?

• No. There is no manufacturer code or EPR registration number required.

Where should I send Delaware customers to recycle?

• Point them to the Delaware Solid Waste Authority (DSWA) website for a list of permanent collection sites.

Are lithium batteries regulated?

• Yes, as of 2026, new federal and state guidelines treat lithium-ion batteries as universal waste to prevent landfill fires.

Do I need to join the CAA for Delaware?

• No, Delaware has not joined the states requiring CAA registration for packaging.

What is Maine EPR EEE

Extended Producer Responsibility for Electrical and Electronic Equipment in Maine is governed by the Electronic Waste Recycling Law (38 M.R.S. §1610). This legislation establishes a shared responsibility model where manufacturers are financially responsible for the collection and recycling of "covered electronic devices" (CEDs). As of 2026, this framework is closely integrated with Maine’s groundbreaking EPR for Packaging Law (LD 1541), which requires producers to also fund the management of the packaging materials associated with these electronic products. The Maine Department of Environmental Protection (DEP) serves as the primary regulator for both electronic waste and packaging stewardship.

Does this apply to e-commerce & online sales

Yes. The law explicitly applies to any entity that sells covered electronic devices "in or into" the state. This includes cross-border e-commerce sellers, distance sellers, and online retailers. If a foreign company sells a covered electronic device to a Maine resident through a website or digital marketplace, that company is legally responsible for ensuring the brand is registered with the DEP and that all associated recycling and packaging fees are paid.

Who is the “producer” under Maine EPR?

Under Maine legislation, the responsible party (producer/manufacturer) is defined as:

1. Brand Owners: Any person who manufactures a covered electronic device under its own brand.

2. Licensees: Any person who sells a device under its own brand produced by other suppliers.

3. Importers: If the brand owner has no physical presence in the United States, the first importer into the U.S. assumes all legal producer responsibilities for the Maine market.

Who must register for EPR packaging in Maine

Manufacturers of covered electronics must register annually with the Maine DEP. Additionally, under the new packaging stewardship rules, producers must register with the Stewardship Organization (SO), which is expected to be the Circular Action Alliance (CAA). Retailers are prohibited from selling any covered electronic device unless the manufacturer is in full compliance and the brand is listed on the DEP’s official registry.

Maine EPR Packaging Registration Threshold

Maine’s E-waste law has no minimum sales threshold for registration; compliance is required from the first unit sold. However, the packaging EPR program (LD 1541) provides a simplified "low-volume" option:

• Low-Volume Producers: Companies that place less than 15 tons of packaging on the Maine market annually can pay a flat fee of $500 per ton instead of detailed reporting.

• Small Business Exemption: Producers with less than $5,000,000 in total gross revenue may qualify for specific exemptions from the packaging stewardship fund.

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Packaging Covered (and Excluded)

The legislation covers both the electronic device and its associated packaging:

1. Covered EEE: Includes televisions, laptops, tablets, e-readers, game consoles, computer monitors, and printers (weighing <100 lbs).

2. Covered Packaging: Includes primary, secondary, and tertiary materials (plastic, paper, glass, metal).

3. Exclusions:

• Motor vehicle components and large appliances.

• Certain medical devices and industrial equipment.

• Packaging used for long-term storage or specialized beverage containers covered by the "Bottle Bill."

Producer Responsibility Organization (PRO)

Maine’s E-waste system operates through state-approved consolidators who invoice manufacturers directly for their "return share" (based on actual waste collected) or "market share." For the packaging component, the Circular Action Alliance (CAA) acts as the designated Stewardship Organization to coordinate municipal reimbursements and manage the packaging waste stream.

EPR Registration in Maine

1. DEP Registration: Submit the Electronic Waste Manufacturer Registration Form to the Maine DEP by July 1st annually.

2. Stewardship Organization Enrollment: Register with the CAA for packaging compliance by May 2026.

3. Fee Payment: Pay the annual registration fee of $3,000 (for market share $\geq$ 0.1%) or $750 (for market share $<$ 0.1%).

Authorized Representative

Foreign manufacturers without a U.S. presence must appoint an Authorized Representative or rely on their first U.S. importer to fulfill all obligations. The AR is responsible for submitting registration forms, reporting annual sales data, and remitting recycling payments to the DEP and the Stewardship Organization.

What Data Must Be Reported

Obligated producers must report:

• Total weight of covered electronic devices sold in Maine.

• Detailed weight and material type of all packaging (plastic, paper, etc.) sold in or into the state.

• National market share data to determine the applicable registration fee tier.

First Reporting Period & EPR Reporting Deadlines

1. Manufacturer Registration: Due annually by July 1st.

2. Packaging Data Reporting: Initial packaging reports to the SO are due in May 2026.

3. Payment Deadlines: Consolidator invoices for E-waste must be paid within 30 days; packaging invoices are typically due by September 1st.

Labels & Marketing Claims

All covered electronic devices must have a permanent label identifying the manufacturer. Packaging must increasingly include accurate recycling instructions and meet state-specific "readily recyclable" criteria. By 2030, at least 50% of packaging must meet these strict recyclability standards to avoid heavy fee surcharges.

EPR Eco Fees & Eco-Modulation

Fees are calculated based on the actual costs of municipal recycling and collection. For packaging, Maine utilizes an eco-modulation model where fees are adjusted based on:

• Recyclability: Lower fees for materials that are easy to process.

• Toxicity: Surcharges for materials containing hazardous substances or "forever chemicals" (PFAS).

• Recycled Content: Incentives for producers using post-consumer recycled materials.

Risks, Penalties & Common Mistakes

• Fines: Penalties for non-compliance can reach $10,000 per day, with some E-waste violations assessed on a per-package basis.

• Market Exclusion: Retailers will be notified to pull non-registered brands from digital and physical shelves.

• Common Mistakes: Forgetting to report tertiary packaging (shipping boxes) and failing to update the DEP registration when new brand names are acquired.

What E-Commerce Sellers Should Do Now

1. Audit Brand Registry: Ensure every electronic brand you sell is registered on the Maine DEP Compliant Manufacturer List.

2. Appoint a Representative: If you are a foreign brand owner, designate a U.S. partner to handle the July 1st filing.

3. Track Packaging Weights: Implement a system to track the weight of shipping boxes and product packaging sent to Maine addresses.

4. Register with CAA: Join the Circular Action Alliance portal before the May 2026 deadline.

5. Review Labeling: Confirm that all electronics have permanent manufacturer labels and that packaging meets new 2026 sustainability guidelines.

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FAQ

Mandatory status

• Registration is mandatory for all manufacturers and distance sellers whose covered electronics enter the Maine market.

Foreign sellers

• Non-U.S. companies must comply through their first U.S. importer or a designated Authorized Representative.

Thresholds

• There is no minimum sales threshold for electronics registration, but packaging producers under 15 tons may use simplified reporting.

Labels

• Each device must carry a permanent manufacturer's mark, and packaging must follow updated recyclability labeling rules by 2026.

Marketplaces

• Online platforms must verify producer compliance to ensure that only registered electronic brands are sold to Maine residents.

What is Maryland EPR EEE

Extended Producer Responsibility (EPR) for electronics in Maryland is governed by the Statewide Electronics Recycling Program (Sections 9-1727 to 9-1730 of the Environment Article). This law requires manufacturers of specific electronic devices to register with the state and contribute to a recycling fund. Additionally, Maryland recently signed SB 901 (the Producer Responsibility Plan for Packaging and Paper Products), which is the first of its kind to allow multiple Producer Responsibility Organizations (PROs) to operate simultaneously. The Maryland Department of the Environment (MDE) is the primary authority overseeing both e-waste and packaging compliance.

Does this apply to e-commerce & online sales

Yes. The law applies to any manufacturer that sells or offers for sale covered electronic devices to any person in Maryland. This specifically includes transactions conducted through sales outlets, catalogs, or the internet. Foreign and out-of-state e-commerce sellers are considered "manufacturers" if they sell directly to Maryland consumers and must ensure their brands are registered before any sales occur.

Who is the “producer” under Maryland EPR?

In Maryland, a "manufacturer" or "producer" is defined as any person:

1. Brand Owners: A person that manufactures a covered device under its own brand or label.

2. Licensees: A person that sells covered devices manufactured by others under a brand that the seller owns or is licensed to use.

3. Importers: A person that imports a covered electronic device manufactured by a person without a physical presence in the United States.

Who must register for EPR packaging in Maryland

All electronic device manufacturers must register annually with the Maryland Department of the Environment (MDE). Under the new packaging law (SB 901), producers must also register with a PRO (such as the Circular Action Alliance) or submit an individual compliance plan to the MDE by July 1, 2026.

Maryland EPR Packaging Registration Threshold

Maryland applies different thresholds for electronics and packaging:

• Electronics: Registration is required if the manufacturer produced an average of more than 1,000 covered electronic devices per year in the preceding 3-year period.

• Packaging (De Minimis): Producers are exempt from the packaging law if they introduced less than 1 ton of covered material into the state or earned global gross revenues of less than $2,000,000 in their most recent fiscal year.

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Packaging Covered (and Excluded)

The Maryland framework covers specific device categories and all associated single-use packaging:

1. Covered EEE: Desktop computers, laptop/notebook computers, computer monitors, and televisions with a screen greater than 4 inches diagonally.

2. Covered Packaging: Single-use packaging made of plastic, paper, glass, or metal.

3. Exclusions:

• Telephones of any type (including smartphones in some contexts).

• Devices that are part of a motor vehicle or a larger piece of industrial/medical equipment.

• Household appliances such as microwave ovens, dishwashers, and refrigerators.

Producer Responsibility Organization (PRO)

The Maryland electronics program is state-managed, with manufacturers paying fees directly to the State Recycling Trust Fund. For the packaging law, Maryland allows for multiple PROs, though the Circular Action Alliance (CAA) is currently the primary approved organization for producers to join.

EPR Registration in Maryland

1. Electronics Registration: Complete the Maryland Electronics Manufacturer Registration Form on the MDE portal.

2. Packaging Enrollment: Join an approved PRO (e.g., CAA) or file an individual plan by July 1, 2026.

3. Fee Payment: Remit the applicable annual fee to the MDE based on prior-year sales volume.

Authorized Representative

Non-U.S. manufacturers are required to appoint a Resident Agent or Authorized Agent located in the United States. This agent serves as the legal point of contact for the MDE, handles registration renewals, and ensures that all mandatory recycling fees are paid on behalf of the foreign producer.

What Data Must Be Reported

Producers must report the following information annually:

• The total number of Covered Electronic Devices (CEDs) sold in Maryland during the prior year.

• A list of all brand names owned or licensed by the manufacturer.

• For packaging, the weight and material type introduced into the Maryland market.

First Reporting Period & EPR Reporting Deadlines

1. E-waste Registration Renewal: Due by March 1st of each year (covering the period from March 1 to February 28).

2. Packaging Producer Registration: Must be completed by July 1, 2026.

3. Initial Packaging Plans: PROs must submit comprehensive plans to the MDE by July 1, 2028.

Labels & Marketing Claims

Manufacturers are prohibited from selling a covered electronic device in Maryland unless it is labeled with the manufacturer’s name or brand label. For packaging, producers must comply with performance goals for recycling, reuse, and waste reduction that will be established in the first five-year stewardship plan.

EPR Eco Fees & Eco-Modulation

Fees for electronics are based on sales volume and program participation:

• 0–99 units sold: $0 (No fee).

• 100–999 units sold: $5,000 initial fee.

• 1,000+ units sold: $10,000 initial fee.

• Take-Back Discount: Manufacturers with an MDE-approved take-back program pay a reduced renewal fee of $500.

Risks, Penalties & Common Mistakes

• Fines: Failure to register or pay fees can lead to administrative penalties and enforcement actions by the MDE.

• Retailer Bans: Retailers are forbidden from selling any brand not listed on the MDE Registered Electronic Manufacturers list; non-compliant brands are blocked from sale.

• Common Mistakes: Failing to renew the registration before the March 1st deadline and neglecting to register all subsidiary brands under the parent company account.

What E-Commerce Sellers Should Do Now

1. Check Brand Status: Verify your electronic brands are on the MDE list for the 2026–2027 cycle.

2. Appoint a U.S. Agent: If you are a foreign seller, ensure your Authorized Agent details are updated with the MDE.

3. Assess Packaging Volume: Determine if your Maryland revenue exceeds $2,000,000 to prepare for the July 2026 packaging registration.

4. Configure Take-Back: Evaluate if implementing a free consumer take-back program can reduce your annual MDE fee from $5,000 to $500.

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FAQ

Mandatory status

• Participation is legally required for any manufacturer or internet seller whose covered electronic products or packaging enter the Maryland market.

Foreign sellers

• Non-U.S. entities must comply through a U.S.-based Authorized Agent and are subject to the same fee structure as domestic manufacturers.

Thresholds

• Electronics registration triggers at an average of 1,000 units annually, while packaging compliance starts at $2,000,000 in global gross revenue.

Labels

• Every electronic device must feature a visible, permanent manufacturer or brand label to be legal for sale in the state.

Marketplaces

• Marketplace facilitators are increasingly responsible for verifying that electronic brands sold on their platforms are registered with the MDE and may block non-compliant listings.

What is Minnesota EPR EEE

Extended Producer Responsibility for Electrical and Electronic Equipment in Minnesota is primarily governed by the Minnesota Electronics Recycling Act (Minn. Stat. § 115A.1310). This law mandates that manufacturers of "Video Display Devices" (VDDs) are responsible for the collection and recycling of "Covered Electronic Devices" (CEDs) from Minnesota households. As of 2026, this exists alongside the newly active Packaging Waste and Cost Reduction Act, which covers the boxes and materials used to ship these electronics. The Minnesota Pollution Control Agency (MPCA) is the lead regulator, while the Minnesota Department of Revenue handles the collection of registration fees.

Does this apply to e-commerce & online sales

Yes. The law explicitly covers any entity that sells or offers for sale covered electronic devices to a household in Minnesota. This includes cross-border e-commerce, catalog sales, and internet-based transactions. If a foreign company ships a VDD directly to a Minnesota consumer, they are legally responsible for registering as a manufacturer and fulfilling recycling obligations.

Who is the “producer” under Minnesota EPR?

Under the Electronics Recycling Act, a "manufacturer" (producer) is defined as:

1. Brand Owners: Any person who manufactures a video display device under its own brand or label.

2. Licensees: Any person who sells a device under a brand that the person owns or is licensed to use.

3. Importers: If the brand owner has no physical presence in the United States, the first importer into the U.S. assumes all producer responsibilities for the Minnesota market.

Who must register for EPR packaging in Minnesota

Every manufacturer of VDDs must register with the MPCA annually. Retailers (including online sellers) are prohibited from selling a VDD brand unless that manufacturer is listed as compliant on the MPCA’s official registry. Additionally, under the 2026 packaging rules, producers must also register with the Circular Action Alliance (CAA) to cover the materials used in shipping and product protection.

Minnesota EPR Packaging Registration Threshold

Minnesota’s electronics law uses a volume-based threshold for fees:

• Registration Fee: A $2,500 annual fee applies if the manufacturer sold 100 or more VDDs to households in the state during the previous calendar year.

• Small Volume: Manufacturers selling fewer than 100 units must still register and report data, but the $2,500 fee is waived.

• Packaging Threshold: For the separate packaging stewardship law, an exemption applies to producers with less than $2 million in global revenue or less than 1 ton of packaging placed in the state.

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Packaging Covered (and Excluded)

The E-waste law focuses on devices, while the packaging law covers the materials:

1. Covered EEE (VDDs): Televisions and computer monitors with a screen size greater than 4 inches diagonally (including laptops and tablets).

2. Covered CEDs (for recycling): Computers, peripherals (keyboards/printers), fax machines, and DVD players.

3. Exclusions:

• Telephones and PDAs (Cell phones are not covered CEDs).

• Motor vehicle components.

• Household appliances (white goods).

• Transport packaging (pallets and industrial crates) used solely for B2B transport.

Producer Responsibility Organization (PRO)

Minnesota’s e-waste program is a manufacturer-run system. Producers often contract with recyclers and collectors to meet their weight-based recycling targets. For the packaging aspect, the Circular Action Alliance (CAA) is the state’s sole approved PRO, and electronics manufacturers must join it to handle their boxes and mailers.

EPR Registration in Minnesota

1. Initial Registration: Submit the VDD Manufacturer Registration Form to the MPCA within 10 days of the first sale.

2. Annual Renewal: Submit a renewal and report previous year’s sales data by August 15th each year.

3. Packaging Registration: Enroll in the CAA portal to ensure the product’s packaging is compliant with the 2026 reporting cycle.

Authorized Representative

Foreign manufacturers with no U.S. location must designate a local Authorized Representative or rely on their Importer of Record. This representative is responsible for filing the annual August 15th return with the Department of Revenue and ensuring that the manufacturer's recycling obligation (based on weight) is fulfilled.

What Data Must Be Reported

Manufacturers must report the following annually:

• The total number of units of VDDs sold to Minnesota households.

• The total weight of VDDs sold (to calculate recycling obligations).

• The total weight of CEDs collected and recycled from Minnesota households to meet their 80% weight-based target.

First Reporting Period & EPR Reporting Deadlines

1. Registration/Reporting: The program year runs from July 1 to June 30. Reports and registration fees are due by August 15th.

2. Sales Reporting: Manufacturers must report their market share of VDDs by March 1st via the Re-Trac Connect system.

3. PFAS Reporting: As of July 1, 2026, manufacturers must also report any intentionally added PFAS in products or components to the MPCA.

Labels & Marketing Claims

Every VDD sold in Minnesota must have a permanent label identifying the manufacturer. Packaging must also move toward standardized "Recyclable" labels. By 2032, all packaging must be fully recyclable, reusable, or compostable to be legally sold in the state.

EPR Eco Fees & Eco-Modulation

For electronics, manufacturers pay a variable Recycling Fee if they fail to meet their collection targets (80% of sales weight). For packaging, the CAA is implementing eco-modulation in 2026, where fees are reduced for packaging that uses post-consumer recycled content or avoids toxic chemicals.

Risks, Penalties & Common Mistakes

• Fines: Failure to register or report can lead to administrative penalties of up to $10,000 per violation.

• Daily Penalties: Packaging EPR violations can incur fines of $25,000 per day for initial offenses.

• Common Mistakes: Forgetting that laptops and tablets are considered VDDs and failing to report "Peripheral" sales weight (printers/keyboards) as part of the total electronic waste stream.

What E-Commerce Sellers Should Do Now

1. Audit SKU List: Identify all screens >4 inches (VDDs) and verify their manufacturer is on the MPCA registry.

2. Track Sales Volume: Monitor if you exceed the 100-unit threshold for the $2,500 registration fee.

3. Join the PRO: Ensure your company is registered with the Circular Action Alliance for your packaging.

4. Prepare PFAS Data: Start gathering chemical disclosure data from suppliers for the July 1, 2026 PFAS reporting deadline.

5. Update Checkout: Inform customers that e-waste recycling is available and provide a link to the MPCA’s collection site map.

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FAQ

• Compliance is mandatory for all manufacturers and distance sellers whose covered electronics or packaging enter Minnesota.

• Non-U.S. companies must comply via an Authorized Representative or their first U.S. importer.

• A $2,500 fee applies for sales of 100+ VDDs; packaging rules apply to those with $2M+ in revenue or 1 ton+ of material.

• Permanent manufacturer branding is required on all devices, and new recyclability standards apply to packaging by 2026.

• Platforms must verify that electronic brands are registered with the MPCA to allow sales to Minnesota households.

What is Oregon EPR EEE

Extended Producer Responsibility for Electrical and Electronic Equipment in Oregon is governed by the Oregon E-Cycles Law, which was significantly updated by House Bill 3220 (2023). This modernized framework, effective January 1, 2026, requires manufacturers to fund and provide a statewide system for the collection and recycling of "Covered Electronic Devices" (CEDs). Additionally, Oregon’s Plastic Pollution and Recycling Modernization Act (SB 582) now regulates the packaging associated with these electronics. The Oregon Department of Environmental Quality (DEQ) oversees the program, ensuring manufacturers take responsibility for their products' end-of-life management.

Does this apply to e-commerce & online sales

Yes. The law explicitly includes any manufacturer "irrespective of the selling technique used, including by means of remote sale." This means that foreign e-commerce companies and out-of-state online retailers shipping covered electronics to Oregon consumers must comply with all registration, fee, and recycling obligations. Online marketplaces are also increasingly monitored to ensure the electronic brands they host are compliant with Oregon’s registry.

Who is the “producer” under Oregon EPR?

Under the modernized 2026 statutes, a "manufacturer" (producer) is defined as:

1. Brand Owners: Any entity that manufactures a covered electronic device under its own brand or label.

2. Licensees: Any person who sells a device under a brand that the person owns or is licensed to use.

3. Importers: If the brand owner has no physical presence in the United States, the entity that first imports the product into the U.S. for sale in Oregon becomes the responsible producer.

Who must register for EPR packaging in Oregon

All manufacturers of covered electronic devices must register annually with the Oregon DEQ. Starting in 2026, manufacturers are also required to designate and join a Producer Responsibility Organization (PRO). For the electronics themselves, manufacturers must join an electronics PRO, while for their packaging, they must register with the Circular Action Alliance (CAA), Oregon's designated packaging PRO.

Oregon EPR Packaging Registration Threshold

Oregon uses a tiered system for electronics and a specific threshold for packaging:

• Electronics Exemption: Manufacturers that sell fewer than 50 covered electronic devices in Oregon per year are exempt from registration and fees.

• Packaging Threshold: Under the Recycling Modernization Act, producers are exempt if they have less than $5 million in global gross revenue or place less than 1 ton of covered packaging on the Oregon market annually.

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Packaging Covered (and Excluded)

The dual framework covers both the hardware and the shipping/product protection:

1. Covered EEE (2026 Expansion): Now includes computers, monitors (>4 inches), televisions, printers, fax machines, VCRs, DVD players, game consoles, portable music players, routers, modems, and scanners.

2. Covered Packaging: Includes all packaging, printing and writing paper, and food serviceware.

3. Exclusions:

• Motor vehicle parts and specialized industrial/medical equipment.

• Telephones of any type (smartphones are currently excluded from the E-waste law).

• 3D printers and large-scale servers.

Producer Responsibility Organization (PRO)

The 2026 law discontinued the "State Contractor Program," mandating that all manufacturers join a private PRO. For electronics, the PRO calculates obligations based on market share. For packaging, the Circular Action Alliance (CAA) is the sole authorized organization responsible for coordinating the statewide recycling system and collecting producer dues.

EPR Registration in Oregon

1. E-waste Registration: Manufacturers must register for the upcoming year between October 15 and December 31.

2. CAA Enrollment: Producers must register on the Circular Action Alliance portal for packaging compliance.

3. Brand Listing: All associated brands (current and past) must be listed in the Electronics Recycling Coordination Clearinghouse (ERCC) portal used by the DEQ.

Authorized Representative

Foreign manufacturers with no U.S. presence must designate a local Authorized Representative or rely on their Importer of Record. This representative is legally responsible for fulfilling the manufacturer’s registration, data reporting, and financial obligations to both the DEQ and the PRO.

What Data Must Be Reported

Producers are required to report:

• Unit Sales: The total number of covered electronic devices sold in or into Oregon.

• Packaging Weight: Total tonnage of packaging materials (plastic, paper, etc.) sold in the prior calendar year.

• Market Share: Data used by the DEQ to assign manufacturers to one of seven fee tiers.

First Reporting Period & EPR Reporting Deadlines

1. Electronics Registration: Must be completed by December 31st for the following program year.

2. Packaging Data Report: The 2025 supply data report is due to the CAA by May 31, 2026.

3. Fee Payments: Packaging fees are typically invoiced in January and July following the reporting cycle.

Labels & Marketing Claims

All covered electronic devices must be permanently labeled with the manufacturer's brand. By 2032, the Recycling Modernization Act mandates that 100% of packaging in Oregon must be recyclable or compostable. Producers must also avoid deceptive environmental claims and ensure all "recyclable" markings align with the Uniform Statewide Collection List.

EPR Eco Fees & Eco-Modulation

• Electronics Fees: Registration fees range from $40 (Tier 7) to $35,000 (Tier 1), depending on market share.

• Packaging Eco-Modulation: In 2026, the CAA is implementing bonuses and surcharges based on packaging design. Discounts are offered for recycled content and high recyclability, while surcharges apply to "difficult-to-recycle" materials.

Risks, Penalties & Common Mistakes

• Fines: Non-compliance can result in civil penalties of up to $25,000 per day.

• Sales Bans: If a manufacturer is not on the DEQ Compliant List, retailers and online platforms are prohibited from selling their products in Oregon.

• Common Mistakes: Assuming that small electronics like routers or scanners are still exempt (they became covered in 2026) and failing to report "shipping packaging" as part of the packaging EPR obligation.

What E-Commerce Sellers Should Do Now

1. Verify VDD/CED Status: Check if your devices now fall under the expanded 2026 definitions (e.g., game consoles, routers).

2. Register with DEQ: Ensure your annual registration is submitted via the ERCC portal by December 31st.

3. Join the CAA: If you ship more than 1 ton of packaging to Oregon, you must join the Circular Action Alliance.

4. Update Product Labels: Ensure every electronic device has a visible brand label.

5. Report May Data: Prepare your 2025 packaging supply data for the May 31, 2026 reporting deadline.

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FAQ

Mandatory status

• Registration and PRO membership are legally required for manufacturers and remote sellers of covered electronics and packaging.

Foreign sellers

• Non-U.S. entities must comply through their first U.S. importer or a designated Authorized Representative.

Thresholds

• Electronics fees apply if selling 50+ units; packaging rules apply to those with $5M+ in revenue or 1 ton+ of material.

Labels

• Permanent manufacturer branding is mandatory on all hardware, and packaging must meet new recyclability standards by 2026.

Marketplaces

• Online platforms must verify that brands are listed as "Compliant" on the DEQ Manufacturer Compliance List before allowing sales to Oregon.

What is Texas EPR EEE

Extended Producer Responsibility (EPR) for electronics in Texas is split into two distinct, manufacturer-led programs: the Texas Recycles Computers Program (Subchapter I) and the Texas Recycles TVs Program (Subchapter J). These laws mandate that manufacturers who sell computer or television equipment in the state must provide consumers with free and convenient recycling options. Unlike some states with unified systems, Texas requires separate compliance pathways for these two categories, all overseen by the Texas Commission on Environmental Quality (TCEQ).

Does this apply to e-commerce & online sales

Yes. The law applies to any manufacturer that sells "in or into" Texas, including online sales and distance selling. If a brand ships covered equipment directly to a Texas resident from outside the state or country, they must be registered and appear on the TCEQ compliant manufacturer list. Retailers (including marketplaces) are prohibited from selling brands that are not listed as compliant.

Who is the “producer” under Texas EPR?

The "manufacturer" (producer) is the entity responsible for compliance. This includes:

1. Brand Owners: Any person who manufactures a covered electronic device under its own brand or label.

2. Licensees: Any person who sells a device under a brand that the person owns or is licensed to use.

3. Importers: If the brand owner has no physical presence in the United States, the entity that first imports the product into the U.S. for sale in Texas assumes the producer's obligations.

Who must register for EPR packaging in Texas

Manufacturers of covered electronics must register with the TCEQ.

• Computer Manufacturers: Must submit a one-time notification and recovery plan. No annual fee is required, but the plan must be updated if brands change.

• TV Manufacturers: Must register annually and pay a fee (unless participating in a Recycling Leadership Program).

• Packaging: Currently, Texas does not have a broad EPR law for packaging (like California's SB 54), but manufacturers should monitor the 2026 legislative session for potential updates.

Texas EPR Packaging Registration Threshold

Texas does not have a de minimis revenue threshold for electronics; obligations are based on the type of equipment sold:

• Computer Equipment: Registration is required for any manufacturer selling their brand in Texas, regardless of volume.

• Televisions: Manufacturers must register and pay a $2,500 annual fee if they choose the "Individual" market share program.

• Small TV Manufacturers: If you join a Recycling Leadership Program (RLP) by January 1st, the $2,500 annual fee is waived.

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Packaging Covered (and Excluded)

The current Texas EPR focus is on the hardware itself:

1. Covered Computer Equipment: Desktops, laptops, monitors, and the accompanying keyboard and mouse (if of the same brand). Tablets are generally included.

2. Covered TV Equipment: Any display device with a tuner that receives broadcast signals.

3. Exclusions:

• Mobile phones and smartphones.

• Computer peripherals sold separately (e.g., a standalone mouse not part of a computer kit).

• Professional/industrial equipment not typically used by households.

Producer Responsibility Organization (PRO)

Texas uses a "Manufacturer-Operated" model rather than a state-run PRO. For TVs, manufacturers can join a Recycling Leadership Program (RLP), which acts as a collective organization to meet collection site requirements and public education goals. For computers, each manufacturer is responsible for their own brand's "take-back" program.

EPR Registration in Texas

1. Computer Registration: File a one-time notification and recovery plan with TCEQ. Ensure your brand is listed on the TexasRecyclesComputers.org database.

2. TV Registration: Submit the Annual Registration and Reporting Form by January 31st each year.

3. RLP Enrollment: To avoid the annual fee, join an approved RLP by January 1st.

Authorized Representative

Foreign manufacturers with no U.S. presence must appoint a local Authorized Representative or agent. This representative handles the TCEQ filings, ensures the brand is correctly listed on the public registry, and manages the logistics of the required free take-back program for Texas consumers.

What Data Must Be Reported

Manufacturers must report annually (by January 31st):

• Total weight of covered equipment sold in Texas during the previous year.

• Total weight of equipment collected and recycled from Texas.

• A current list of all brands sold by the manufacturer.

• Documentation of environmental management practices used by their recyclers.

First Reporting Period & EPR Reporting Deadlines

1. January 1st: Deadline to join a Recycling Leadership Program (RLP) to waive TV fees.

2. January 31st: Deadline for annual TV registration, annual reports, and payment of the $2,500 fee (if applicable).

3. Continuous: Computer manufacturers must update their recovery plans immediately if they add or remove brands.

Labels & Marketing Claims

Manufacturers are prohibited from selling new computer or TV equipment in Texas unless it is labeled with the manufacturer’s brand. The label must be permanently affixed and readily visible. Manufacturers must also provide consumers with information on how to recycle the device for free (typically via a link on their website).

EPR Eco Fees & Eco-Modulation

Texas does not currently use eco-modulation (bonuses for green design).

• Computer Fee: $0 (No registration fee).

• TV Fee: $2,500 annually for the individual program; $0 if in an RLP.

  Manufacturers are responsible for all costs associated with their take-back programs, including shipping or collection site fees.

Risks, Penalties & Common Mistakes

• Fines: Violations of the TV recycling law can result in penalties of up to $2,500 per day. TCEQ environmental violations can reach $25,000 per day.

• Market Access: If your brand is not on the TCEQ compliant list, it is illegal for any retailer or marketplace to sell your product in Texas.

• Common Mistakes: Failing to register a new sub-brand and assuming that "small" e-commerce sellers are exempt from the take-back requirement.

What E-Commerce Sellers Should Do Now

1. Check the Registry: Ensure your brand is listed on the TCEQ "Manufacturers Meeting the Requirements" list.

2. Review TV Deadlines: If you sell TVs, ensure your $2,500 fee or RLP membership is settled before the January 31st deadline.

3. Verify Labels: Confirm all products shipped to Texas have a permanent brand label.

4. Publish Take-Back Info: Add a clear "Recycle this product" link to your website for Texas customers.

5. Monitor Packaging Laws: While Texas is hardware-focused, watch for the introduction of packaging-specific EPR bills in the 2026 legislative cycle.

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FAQ

Is there a sales threshold to be exempt in Texas?

• No, any manufacturer selling covered electronics in Texas must register and provide a take-back program, regardless of sales volume.

Can I charge a consumer a fee for recycling their old device?

• No, the law mandates that the recycling program must be free to the consumer at the point of return.

Are smartphones covered under Texas EPR?

• No, the current Texas laws only cover "Computer Equipment" (laptops, desktops, monitors) and "Television Equipment."

What happens if my manufacturer is not registered?

• It is illegal for you to sell that brand in Texas. You could face fines and be forced to stop all sales to Texas residents.

Who pays for the shipping of recycled electronics?

• The manufacturer must cover the costs, which usually involves providing a pre-paid shipping label or a local drop-off point.

What is Virginia EPR EEE

Extended Producer Responsibility (EPR) for electronics in Virginia is regulated under the Virginia Computer Recovery and Recycling Act (§ 10.1-1425.27 et seq.). This law requires manufacturers of "Covered Computer Equipment" to provide consumers with a free and convenient system for recycling their branded products. The program is "manufacturer-operated," meaning each brand is responsible for its own recovery infrastructure, all of which is overseen by the Virginia Department of Environmental Quality (DEQ).

Does this apply to e-commerce & online sales

Yes. The law applies to any manufacturer that "sells or offers for sale" covered equipment in Virginia. This explicitly includes internet sales, catalog sales, and any other distance-selling method. If you ship a branded laptop or monitor to a Virginia resident via an online transaction, you are legally considered a manufacturer and must be registered with the DEQ.

Who is the “producer” under Virginia EPR?

A "manufacturer" (producer) in Virginia is defined as anyone who:

1. Brand Owners: Manufactures computer equipment under its own brand or label.

2. Licensees: Sells equipment under its own brand produced by others.

3. Importers: If the brand owner has no physical presence in the U.S., the first importer into the country who sells the product in Virginia assumes all legal manufacturer obligations.

Who must register for EPR packaging in Virginia

Manufacturers of covered computer equipment must register with the DEQ.

• Electronics Registration: Mandatory if you sold more than 500 units of your brand in Virginia in the previous calendar year.

• Packaging: As of March 2026, Virginia does not have a mandatory statewide packaging EPR law (like California's SB 54). While packaging EPR bills have been discussed in the 2025–2026 legislative sessions, they have not yet been enacted into law.

Virginia EPR Packaging Registration Threshold

Virginia's law includes a specific unit-based threshold for electronics:

• The 500-Unit Rule: You are only required to register and provide a recovery plan if you manufacture and sell (or offered for sale) more than 500 units of computer equipment in Virginia under your brand.

• Reporting Threshold: Even if you meet the 500-unit sale threshold, there is no state-mandated fee per unit; the obligation is to fund the recycling system itself.

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Packaging Covered (and Excluded)

The Virginia law is narrowly focused on specific computer hardware:

1. Covered Computer Equipment: Desktop computers, notebook/laptop computers, and computer monitors.

2. Exclusions:

• Televisions (covered in other states, but excluded from Virginia’s Computer Act).

• Personal Digital Assistants (PDAs) and Telephones/Smartphones.

• Computer peripherals sold separately (e.g., keyboards or mice not bundled with a computer).

• Equipment leased to a consumer.

Producer Responsibility Organization (PRO)

Virginia does not utilize a centralized state PRO. It is a Manufacturer-Operated Program. Manufacturers must either:

• Develop their own Individual Recovery Plan (e.g., mail-back programs).

• Partner with a third-party recycler to provide collection sites.

• There is no requirement to join a collective group, though many brands coordinate through national recycling networks.

EPR Registration in Virginia

1. Annual Registration: Submit your Computer Manufacturer Registration Form to the DEQ by January 31st of each year.

2. One-Time Registration: If it is your first time selling in the state, you must file before your products can be legally sold.

3. Registry: Your brand must appear on the DEQ's "Manufacturers with a Recovery Plan" list to stay legal for retail and online sales.

Authorized Representative

Foreign manufacturers with no U.S. presence must designate an Authorized Representative or rely on their first U.S. importer. This person is responsible for submitting the recovery plan and certifying that the recycling process meets Virginia’s "sound environmental management" standards.

What Data Must Be Reported

Manufacturers must publish an annual report on their own website and provide a copy to the DEQ by January 31st:

• The weight of computer equipment collected, recycled, and reused during the preceding year.

• The contact information for the representative responsible for the recovery plan.

• Certification that the recycling complies with Virginia’s environmental standards (§ 10.1-1425.38).

First Reporting Period & EPR Reporting Deadlines

1. January 31, 2026: Deadline for annual reports and registration renewals for the 2026 program year.

2. July 1, 2026: Implementation of the expanded polystyrene (foam) container ban for all food vendors (a related packaging-waste law).

3. Ongoing: New brands must be registered with the DEQ before being offered for sale.

Labels & Marketing Claims

• Manufacturer Label: All new computer equipment sold in Virginia must be permanently labeled with the manufacturer's brand.

• Retailer Obligation: Retailers are prohibited from selling any brand of computer equipment that is not listed on the DEQ's compliant manufacturer list.

• Consumer Info: Manufacturers must include recycling information on their website and may include it in the product's packaging.

EPR Eco Fees & Eco-Modulation

• No Point-of-Sale Fee: Unlike California, Virginia does not charge an "Advanced Recycling Fee" at the register.

• Free to Consumer: The manufacturer’s recovery plan must allow the consumer to recycle the branded equipment at no charge.

• Internalized Costs: Manufacturers are expected to internalize the cost of the recycling program.

Risks, Penalties & Common Mistakes

• Sales Block: If your brand is not on the DEQ list, retailers (including Amazon and other marketplaces) are legally required to stop selling your products to Virginia residents.

• Fines: Failure to implement a recovery plan or file reports can result in civil penalties under Virginia's waste management laws.

• Common Mistakes: Failing to report the weight of collected goods by the January 31st deadline and assuming that "tablets" are exempt (they are often categorized as portable computers).

What E-Commerce Sellers Should Do Now

1. Audit Sales Volume: Check if you sold more than 500 units of computer equipment (monitors/laptops) in Virginia last year.

2. Verify DEQ Listing: Ensure your brand is officially listed on the Virginia DEQ website.

3. Review Mail-Back Programs: If you don't have physical sites, ensure your mail-back program is "reasonably convenient" for Virginia residents.

4. Update Data Policies: Under the 2026 VCDPA amendments, ensure you provide instructions to consumers on how to permanently erase personal data before recycling.

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FAQ

Is registration required for printers in Virginia?

• No, printers are considered peripherals and are currently excluded from the mandatory Computer Recovery and Recycling Act.

Do I have to pay a state registration fee?

• No, Virginia does not currently charge an administrative fee for filing the Computer Manufacturer Registration.

What if I sell only to businesses?

• The law applies to "Consumers," defined as individuals using equipment for personal or home-business use. B2B contracts that address end-of-life management can be exempt.

Is there a packaging tax in Virginia?

• Not yet. Only specific items like polystyrene containers (foam) are being restricted as of 2026.

Can I charge for a recycling shipping label?

• No, the collection and recycling under your recovery plan must be provided to the consumer at no charge.

What is Washington EPR EEE

Extended Producer Responsibility for Electrical and Electronic Equipment in Washington is governed by the Electronic Product Recycling Law (RCW 70A.300). This legislation established the E-Cycle Washington program, which requires manufacturers to fund the collection and recycling of "Covered Electronic Products" (CEPs) from households, small businesses, schools, and non-profits. The Washington State Department of Ecology is the primary regulator, overseeing the transition to a sustainable, producer-funded system that has been operational since January 1, 2009.

Does this apply to e-commerce & online sales

Yes. The law applies to any manufacturer that sells covered electronic products "in or into" the state of Washington. This explicitly includes online retailers, cross-border e-commerce sellers, and catalog sales. If a foreign entity ships a covered electronic device to a Washington consumer via an internet transaction, that entity is legally considered a producer and must comply with registration and fee requirements.

Who is the “producer” under Washington EPR?

In Washington, the "manufacturer" (producer) responsible for compliance is defined as:

1. Brand Owners: Any person who manufactures a covered electronic product under its own brand or label.

2. Licensees: Any person who sells a device under its own brand produced by others.

3. Importers: If the brand owner has no physical presence in the United States, the first importer into the U.S. who sells the product in Washington assumes all legal producer responsibilities.

Who must register for EPR packaging in Washington

All manufacturers of covered electronic products must register annually with the Washington Department of Ecology. Retailers (including online platforms) are prohibited from selling any brand of CEP unless the manufacturer is listed as "In Compliance" on the Department of Ecology’s official registry. Additionally, under the 2025 Recycling Reform Act, producers must also prepare to register their packaging with the Circular Action Alliance (CAA).

Washington EPR Packaging Registration Threshold

Washington uses a market-share-based tier system for electronics:

• Registration Tiers: Manufacturers are assigned to one of six tiers based on their annual unit sales in the state.

• Tier 6 Exemption: Manufacturers in the lowest tier (those with a market share of less than 0.01%) are required to register and report but pay an administrative fee of $0.

• Packaging Threshold: For the separate packaging law, exemptions typically apply to producers with less than $1,000,000 in revenue or those placing less than 1 ton of packaging on the market.

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Packaging Covered (and Excluded)

The dual framework in Washington covers the hardware and its associated waste:

1. Covered EEE (CEPs): Televisions, computers (desktops and laptops), computer monitors, and portable DVD players.

2. Covered Packaging: Includes all primary and shipping packaging (plastic, paper, cardboard) used to deliver the electronics.

3. Exclusions:

• Computer peripherals (keyboards, mice, printers).

• Mobile phones and PDAs.

• Devices that are functionally or physically part of a larger piece of equipment (e.g., motor vehicle dashboard displays).

Producer Responsibility Organization (PRO)

The Washington Materials Management & Financing Authority (WMMFA) is the statutory PRO created to operate the "Standard Plan." Most manufacturers are automatically members of the WMMFA, which manages the collection and recycling infrastructure. For the new packaging regulations, the Circular Action Alliance (CAA) is the designated PRO for stewardship.

EPR Registration in Washington

1. Annual Registration: Submit your brand list and registration via the Department of Ecology’s online portal by January 1st.

2. WMMFA Participation: Most manufacturers participate in the WMMFA Standard Plan; however, producers may opt to submit an "Independent Plan" if they meet strict state criteria.

3. Brand Verification: Ensure all sub-brands and subsidiary labels are listed accurately in the state database to prevent retail blocks.

Authorized Representative

Foreign manufacturers with no U.S. office must designate a local Authorized Representative or rely on their Importer of Record. This representative is responsible for the annual January 1st registration filing and for paying the administrative fees to the Department of Ecology on behalf of the manufacturer.

What Data Must Be Reported

Producers must report the following annually:

• The total number of units of covered electronic products sold in Washington.

• A comprehensive list of all brand names under which the products are sold.

• For the packaging aspect, the total weight and material type of packaging introduced into the state.

First Reporting Period & EPR Reporting Deadlines

1. Annual Registration: Due by January 1st for the upcoming calendar year.

2. Fee Tier Notification: The Department of Ecology notifies manufacturers of their assigned fee tier by August 1st.

3. Packaging Registration: Producers must join the designated packaging PRO by July 1, 2026.

Labels & Marketing Claims

Since January 1, 2007, all covered electronic products sold in Washington must have a permanently affixed, readily visible label identifying the manufacturer. "White box" or unbranded products are prohibited. Packaging must also comply with new "Truth in Labeling" standards to ensure recycling claims are substantiated by local infrastructure.

EPR Eco Fees & Eco-Modulation

Fees for electronics are based on a 6-tier scale:

• Tier 1 (High Share): Fees can exceed $30,000 annually.

• Tier 6 (Low Share): $0 administrative fee.

  For packaging, the 2026 framework will introduce eco-modulation, providing discounts for packaging that uses high levels of post-consumer recycled (PCR) content.

Risks, Penalties & Common Mistakes

• Fines: Failure to register or label products can result in civil penalties of up to $10,000 per violation.

• Stop-Sale Orders: Retailers are forbidden from selling any brand not listed as "In Compliance" on the Department of Ecology website.

• Common Mistakes: Failing to report laptops and tablets as computers and neglecting to register new brands within 30 days of their introduction to the market.

What E-Commerce Sellers Should Do Now

1. Audit Brand Compliance: Verify that all electronic brands you sell are listed on the E-Cycle Washington Manufacturer List.

2. Appoint a U.S. Agent: If you are a foreign seller, ensure your Authorized Representative is registered with the state.

3. Configure Labels: Confirm that every electronic device has a visible, permanent brand label before shipping.

4. Prepare for Packaging: If your sales exceed 1 ton of packaging, prepare to register with the Circular Action Alliance by 2026.

5. Update Checkout Information: Provide a link on your website to the E-Cycle Washington collection site map for your customers.

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FAQ

Mandatory status

• Registration and funding are mandatory for all manufacturers and remote sellers of covered electronics in Washington.

Foreign sellers

• Non-U.S. companies must comply through a U.S.-based Authorized Representative or their first U.S. importer.

Thresholds

• Fee tiers are based on market share, with very small manufacturers (Tier 6) paying no administrative fee but still requiring registration.

Labels

• Permanent manufacturer branding is required on all hardware; unbranded "white box" devices are illegal for sale in Washington.

Marketplaces

• Online platforms must verify that electronic brands are registered with the state to remain legal for sale to Washington residents.

What is California Battery EPR

As of January 1, 2026, California has officially launched one of the most comprehensive battery recycling programs in the world. This is governed by two major pieces of legislation:

• SB 1215 (Battery-Embedded Products): Expands the existing E-Waste Recycling Act to include products with non-removable batteries (e.g., electric toothbrushes, smartwatches, wireless earbuds).

• AB 2440 (Responsible Battery Recycling Act): Creates a traditional EPR framework for "loose" batteries (rechargeable and primary) where producers must fund and operate a stewardship program.

Does this apply to e-commerce & online sales

Yes. Any retailer, including online marketplaces and e-commerce sellers, shipping covered products to a California address must comply.

• Retailer Registration: You must register with the California Department of Tax and Fee Administration (CDTFA) to collect and remit the new fees.

• Marketplace Facilitators: Large platforms (like Amazon or eBay) are generally responsible for collecting the fee on behalf of 3rd-party sellers, similar to sales tax.

Who is the “producer” under California Battery EPR?

The definition depends on the product type:

1. For Embedded Products (SB 1215): The Manufacturer of the device (or the brand owner/importer) is the responsible party.

2. For Loose Batteries (AB 2440): The Producer is the person who manufactures the battery, owns the brand/trademark, or is the first importer into California.

Who must register for Battery EPR in California

• Retailers/Sellers: Must register with the CDTFA for a Covered Battery-Embedded (CBE) Waste Recycling Fee account.

• Producers (Loose Batteries): Must join an approved Battery Stewardship Organization (BSO).

• Manufacturers (Embedded): Must provide annual notices to retailers and CalRecycle listing their covered and exempt products.

California Battery EPR Fees & Thresholds

• Point-of-Sale Fee: Effective January 1, 2026, a recycling fee of 1.5% of the retail price is charged to the consumer.

• Fee Cap: The fee is capped at a maximum of $15.00 per item.

• Threshold: There is no minimum unit threshold; if you sell one covered battery-embedded product into California, the fee applies.

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Products Covered (and Excluded)

Covered (CBEP)

• Small electronics with non-removable batteries (vacuum cleaners, power tools, toys).

• Wearables (smartwatches, health trackers).

• Loose household batteries (AAA, AA, C, D, 9V, Button Cells).

• Lithium-ion batteries (up to 5kg/300Wh for rechargeables).

Excluded

• Lead-acid batteries (covered under a separate 1980s-era law).

• Medical devices (prescribed by a healthcare provider).

• Motor vehicle batteries (traction batteries for EVs are managed differently).

• Large batteries (Primary >2kg; Rechargeable >5kg or >300Wh).

Producer Responsibility Organization (PRO/BSO)

For loose batteries, producers must participate in an approved Battery Stewardship Organization (BSO). These organizations manage the collection sites and recycling logistics. For battery-embedded products (SB 1215), the state manages the funds via the CDTFA and pays recyclers directly.

EPR Registration & Reporting

• Retailer Registration: Portal is active at the CDTFA website.

• First Return Deadline: Your first quarterly return (for Jan–March 2026) is due April 30, 2026.

• Manufacturer Reporting: Manufacturers of embedded products must submit an annual report to CalRecycle starting July 1, 2027, covering 2026 sales data.

Authorized Representative

Foreign manufacturers of loose batteries must appoint a U.S.-based Authorized Representative to participate in a BSO. For embedded products, the Importer of Record into California typically assumes the retailer’s obligation if the brand owner is not registered.

Labels & Marketing Claims

• Brand Identification: Every covered product must be permanently labeled with the manufacturer’s brand.

• Chemistry Labeling: By 2026, manufacturers must provide battery chemistry information either on the product or via a clearly accessible website/QR code.

• Invoices: The fee must be explicitly stated on the customer's receipt as the "CA Battery-Embedded Recycling Fee."

Risks, Penalties & Common Mistakes

• Sales Stop: Retailers are prohibited from selling products from manufacturers who have not submitted their required notices to CalRecycle.

• Remittance Fines: Failure to remit the 1.5% fee to the CDTFA can result in tax penalties and interest, similar to sales tax evasion.

• Misclassification: A common mistake is failing to charge the fee on "refurbished" items—the law applies to both new and refurbished products.

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FAQ

Is the fee based on the battery or the whole product?

• The 1.5% fee is calculated on the entire retail sales price of the battery-embedded product.

What if the battery is "easily removable"?

• If a user can remove the battery with common household tools, it is not a CBEP (embedded product). It is then regulated as a "loose battery" under the AB 2440 stewardship program.

Do I need a separate account for e-waste and batteries?

• Yes, the CDTFA has established a specific account type for the Covered Battery-Embedded Waste Recycling Fee.

Does this replace the existing TV/Monitor fee?

• No. If a device is already a "Covered Electronic Device" (like a laptop with a screen >4"), it follows the existing e-waste fee structure. SB 1215 covers the other battery-powered items.

What is Colorado Battery EPR

As of March 2026, Colorado is implementing the Battery Stewardship Act (SB 25-163), which was passed in 2025. This law creates a mandatory Extended Producer Responsibility (EPR) framework for small- and medium-format batteries. Unlike California’s "point-of-sale fee" model, Colorado uses a Producer-Funded model where the companies that sell batteries (or products containing them) must pay to run the recycling system themselves.

Does this apply to e-commerce & online sales

Yes. The law applies to any producer selling, making available for sale, or distributing covered batteries or battery-containing products "in or into" the state. This explicitly covers online retailers and e-commerce platforms.

• Direct Sales: If you ship to a Colorado zip code, you are responsible.

• Prohibition: Starting in 2028, it will be illegal for any retailer (online or physical) to sell batteries from a producer that is not part of an approved stewardship program.

Who is the “producer” under Colorado Battery EPR?

The hierarchy of responsibility is as follows:

1. Brand Owners: The person who manufactures the battery and sells it under their own brand.

2. Licensees: The person who owns or is the licensee of a brand or trademark under which the battery is sold.

3. Importers: If the brand owner has no presence in the U.S., the first importer into the state is the "producer."

Who must register for Battery EPR in Colorado

• Producers: Must join and finance a Battery Stewardship Organization (BSO).

• BSOs: Must register with the Colorado Department of Public Health and Environment (CDPHE). The first formal stewardship plans from these organizations are due by July 1, 2027.

• Note on Packaging: Separate from batteries, if you sell packaging in Colorado, you must already be registered with the Circular Action Alliance (CAA) as of January 1, 2026.

Colorado Battery EPR Thresholds & Fees

• No Consumer Fee: It is illegal for retailers to charge a specific "recycling fee" to consumers at checkout to cover EPR costs.

• Producer Dues: Producers pay annual dues to their BSO.

• Small Format: Includes primary (single-use) batteries up to 4.4 lbs and rechargeable batteries up to 11 lbs.

• Medium Format: Includes primary batteries between 4.4–25 lbs and rechargeables between 11–200 lbs.

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Products Covered (and Excluded)

Covered

• Loose Batteries: Alkaline, Lithium-ion, Nickel-cadmium, etc.

• Removable Batteries: Batteries that can be easily removed from products (tools, toys, laptops).

• Medium-Format: Larger batteries used in E-bikes, E-scooters, and backup power systems.

Excluded

• Lead-Acid Batteries: Covered under existing automotive laws.

• Medical Devices: If not sold at retail.

• EV Batteries: Currently excluded from the 2025 Act, but SB 26-003 (introduced in Jan 2026) is currently moving through the legislature to add them.

Producer Responsibility Organization (PRO/BSO)

The state expects producers to join a BSO (likely Call2Recycle or a similar industry group) which will submit the first official state plan by July 2027. For general packaging, the PRO is the Circular Action Alliance (CAA).

EPR Registration & Reporting

• July 1, 2027: Deadline for BSOs to submit their plans.

• January 1, 2028: Mandatory labeling requirements begin (producers must be identified on the battery).

• January 1, 2029: Landfill ban on covered batteries goes into effect.

Authorized Representative

Foreign producers must appoint a U.S.-based Authorized Representative to participate in the BSO and handle all financial obligations and data reporting.

Labels & Marketing Claims

• Producer ID: Batteries must be marked to identify the producer.

• Warning Labels: By 2028, specific "Do Not Trash" or "Recycle" iconography must be present on the battery or its packaging.

• Eco-Modulation: Dues paid by producers will be adjusted (eco-modulated) starting in 2028 based on how easy the battery is to recycle or the toxicity of its materials.

Risks, Penalties & Common Mistakes

• Market Access Risk: If your brand is not registered with a BSO by the 2028 deadline, your products will be delisted from Colorado retail (including Amazon/Marketplaces).

• Fire Liability: Colorado is passing strict safety standards for BSOs to minimize "thermal runaway" events in collection bins; producers share the liability for these standards.

• Common Mistakes: Confusing the Packaging EPR (live now in 2026) with the Battery EPR (plans due 2027, implementation 2028). You need to be compliant with both.

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FAQ

Do I have to register for batteries in 2026?

• You should be identifying which BSO you will join, but the formal "plan" stage for batteries begins in 2027. However, if your batteries come in a cardboard box, you must be registered for Packaging EPR right now.

Are EV batteries included?

• Not in the current Battery Stewardship Act, but a new bill (SB 26-003) is being debated right now in the 2026 session to include them.

Can I charge my customer for the recycling cost?

• No. You can raise your wholesale price, but you cannot add a separate "recycling fee" line item on the receipt in Colorado.

Is there a Right to Repair?

• Yes, Colorado has a robust Right to Repair law (updated in 2026) that allows consumers to use third-party parts for electronic repairs.

What is Maine Battery EPR

As of March 2026, Maine is finalizing the transition to a modern Extended Producer Responsibility (EPR) framework for batteries. Historically, Maine only required recycling for nickel-cadmium (Ni-Cd) and small sealed lead-acid (SSLA) batteries. However, under the 2025–2026 "Battery Program Modernization" initiative (advancing from LD 474/LD 2130), the state is expanding coverage to include Lithium-ion and Primary (single-use) batteries.

The program is managed by the Maine Department of Environmental Protection (DEP) and follows a Producer-Funded model where manufacturers must finance the collection and processing of batteries to prevent landfill fires and recover critical minerals.

Does this apply to e-commerce & online sales

Yes. The law applies to any producer that "sells, offers for sale, or distributes" covered batteries or battery-containing products in or into Maine, including through internet transactions.

• Sales Ban: By 2028–2029, it will be illegal for any retailer or online marketplace to sell batteries from a producer that is not participating in an approved stewardship program.

• Shipping: E-commerce sellers must comply with specific packaging and "Universal Waste" shipping standards for lithium batteries sent from or into the state.

Who is the “producer” under Maine Battery EPR?

Maine uses a "cascading" definition to identify the responsible party:

1. Brand Owners: The person who manufactures the battery or product and sells it under their own brand.

2. Licensees: If the manufacturer is not in the U.S., the licensee of the brand/trademark in the state.

3. Importers: If neither of the above applies, the first importer into the state is the producer.

• Note: A retailer is only the "producer" if they sell a private-label brand or if the actual manufacturer is not registered.

Who must register for Battery EPR in Maine

• Producers: Must join a Battery Stewardship Organization (BSO). While the final BSO for the new 2026 standards is being contracted, many producers currently use Call2Recycle.

• Packaging Registration: Crucial Deadline! If you sell batteries in Maine, you are likely a "Producer of Packaging" under LD 1541. You must register and report your 2025 packaging data by May 2026 (see deadlines below).

Maine Battery EPR Thresholds & Fees

• Weight Limits:

  • Portable Batteries: Rechargeable batteries up to 11 lbs and primary batteries up to 4.4 lbs.

  • Medium-Format: Rechargeable batteries between 11–25 lbs (or up to 2,000 Wh).

• No Point-of-Sale Fee: Unlike California, Maine does not charge a consumer fee at the register. Producers must "internalize" the cost into the product price.

• Start-Up Fees: Producers must remit start-up fees to the state's selected Stewardship Organization (SO) within 180 days of the contract being finalized (expected September 2026).

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Products Covered (and Excluded)

Covered

• Lithium-ion batteries (the primary focus of the 2026 modernization).

• Alkaline/Primary batteries (AAA, AA, C, D, 9V).

• Removable batteries in power tools, laptops, and toys.

• E-Bike/E-Scooter batteries (Medium-format).

Excluded

• Embedded Batteries: Batteries not intended to be removed by the user (these will be added to the program starting January 1, 2030).

• Lead-Acid Batteries >11 lbs: Covered under a separate mandatory deposit/take-back system ($10 core charge).

• Medical Devices: If they must be treated as biomedical waste.

Producer Responsibility Organization (PRO/SO)

Maine is unique because it uses a state-selected Stewardship Organization (SO) rather than a private PRO like the Circular Action Alliance (CAA) for its packaging.

• For Packaging, the DEP is issuing the RFP in early 2026 and expects to contract with an SO by Spring 2026.

• For Batteries, producers generally coordinate through Call2Recycle while the state finalizes the modernized oversight rules.

EPR Registration & Reporting

• May 2026: Deadline for producers to register and report estimated 2025 packaging data to the state's SO.

• Annual Reporting: Once the battery program is fully operational, producers will report the total weight of batteries sold into the state annually.

Authorized Representative

Foreign producers or those without a physical presence in Maine must appoint a U.S.-based Authorized Representative to fulfill their registration, reporting, and financial obligations.

Labels & Marketing Claims

• "Do Not Trash": Batteries (or their packaging) must feature clear iconography indicating they cannot be disposed of in municipal waste.

• Producer ID: The battery must be traceable to the registered producer.

Risks, Penalties & Common Mistakes

• Packaging Overlap: Many battery sellers forget they are also "Packaging Producers." Failure to register for packaging by May 2026 can result in fines of $10,000+.

• Fire Liability: With Maine's new focus on lithium-ion safety, producers can be held liable for costs associated with fires caused by non-compliant battery disposal.

• Common Mistakes: Assuming that "Small Quantity" sellers are exempt. While Maine has a "de minimis" for small businesses, you must still document your status to avoid the registration mandate.

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FAQ

Is there a battery fee in Maine?

• No consumer-facing fee. Producers pay the SO, and the SO reimburses municipalities.

What if my battery is "embedded" and can't be removed?

• You are currently exempt from the battery stewardship fee until January 1, 2030, but the packaging of that product is still regulated now.

When do the first actual payments start?

• Start-up fees are due in September 2026, with the first full annual payments for packaging/batteries occurring in 2027.

What is Minnesota Battery EPR

As of March 16, 2026, Minnesota's battery recycling landscape is defined by two distinct frameworks: a long-standing mandatory collection law for specific rechargeables and a new 2026 Producer Stewardship Act currently moving through the legislature to cover all portable and medium-format batteries.

• Current Law (Minn. Stat. 115A.9157): Manufacturers of rechargeable batteries (Ni-Cd and SSLA) and products with non-removable batteries must already provide a free recycling program to consumers.

• The 2026 Shift: During the current 2026 Legislative Session (Feb 17 – May 18, 2026), Minnesota is prioritizing a comprehensive EPR bill that would establish a Producer Responsibility Organization (PRO) to handle all battery chemistries, including primary alkaline and lithium-ion, funded entirely by manufacturers.

Does this apply to e-commerce & online sales

Yes. Existing laws and the proposed 2026 expansion apply to anyone who "sells or offers for sale" products into Minnesota.

• Marketplace Responsibility: Under the 2026 framework, online marketplaces are being held to stricter "gatekeeper" standards, meaning they cannot legally list brands that are not registered with an approved stewardship plan.

• Existing Requirement: If you sell rechargeable-battery products online to MN residents, you must already be a licensee of a program like The Battery Network (Call2Recycle) or have a state-approved independent plan.

Who is the “producer” under Minnesota EPR?

Under the 2026 Stewardship Plan, the "Producer" is identified as:

1. Brand Owners: Companies that manufacture a battery-powered device under their own brand.

2. Importers: The first person to import a covered product into the state if the brand owner has no U.S. presence.

3. Private Labelers: Retailers who sell batteries or devices under their own house brand.

Who must register for Battery EPR in Minnesota

• Rechargeable Manufacturers: Must already be registered and reporting to the Minnesota Pollution Control Agency (MPCA).

• Packaging Producers: Urgent! Minnesota passed a Packaging EPR law in 2024. Producers must appoint a PRO by January 1, 2026, and register with that PRO by July 1, 2026.

• All Battery Producers: If the 2026 Battery Bill passes this May, all brands selling any battery types will need to join a PRO by early 2027.

Minnesota EPR Thresholds & Fees

• No Consumer Fee: Unlike California, Minnesota does not permit a separate "eco-fee" at the register. Producers must pay the PRO directly.

• Weight Limits (2026 Proposed):

  • Portable Batteries: Up to 4.4 lbs (primary) and 11 lbs (rechargeable).

  • Medium-Format: Between 11 lbs and 200 lbs (covering e-bikes and small energy storage).

• PFAS Reporting: Starting July 1, 2026, manufacturers must report any products sold in MN that contain intentionally added PFAS (common in some battery coatings).

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Products Covered (and Excluded)

Covered

• Loose Batteries: Alkaline, Lithium, Zinc-carbon, etc.

• Removable & Non-removable: If the product contains a rechargeable battery, it is covered.

• E-waste: Monitors, laptops, and TVs are covered under a separate, older E-waste law.

Excluded

• Motor Vehicles: Traditional lead-acid car batteries and EV propulsion batteries are excluded from the stewardship network, though they are still subject to strict landfill bans.

• Medical Devices: Specifically those that are not sold at retail.

Producer Responsibility Organization (PRO)

• Batteries: Most brands currently satisfy MN law through Call2Recycle. A centralized PRO for all batteries is expected to be designated by late 2026.

• Packaging: The state is currently selecting a Stewardship Organization (SO) with a contract expected by April 2026.

EPR Registration & Reporting

• March 31, 2026: Deadline for manufacturers of rechargeable batteries to report the weight of products sold and collected in MN over the last two years (odd-numbered year reporting).

• July 1, 2026: Deadline to register with a PRO for the Packaging EPR program.

Authorized Representative

Foreign producers with no physical presence in Minnesota must appoint a U.S.-based Authorized Representative to handle reporting to the MPCA and financial transactions with the PRO.

Labels & Marketing Claims

• Removability: Minnesota law (Stat. 325E.125) prohibits the sale of many rechargeable consumer products unless the battery can be easily removed or is in a separate pack.

• Identification: Every battery and product must be labeled with the brand and the battery chemistry (QR codes are often used to meet this requirement in 2026).

Risks, Penalties & Common Mistakes

• Hefty Packaging Fines: Under the new packaging law, initial violations can reach $25,000 per day.

• PFAS Non-Compliance: Failing to report PFAS-containing components by July 1, 2026, can trigger a sales ban on those specific SKUs.

• Common Mistakes: Assuming that "recyclable" packaging is exempt from the PRO—all packaging is subject to reporting and fees in Minnesota.

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FAQ

• Is there a landfill ban on batteries in Minnesota?

  Yes. It is illegal to place any rechargeable battery (or product containing one) in the general trash.

• When does the Packaging EPR fee start?

  Producers will begin covering 50% of program costs in 2029, but registration and data collection are required now in 2026.

• Are EV batteries free to recycle?

  No. In 2026, EV batteries are treated as Hazardous Waste and are excluded from consumer drop-off programs. Manufacturers must manage these via professional ITAD/Recycling contracts.

What is Washington Battery EPR

As of March 16, 2026, Washington State is in the active implementation phase of the Responsible Battery Management Act (SB 5144). This law established a comprehensive Extended Producer Responsibility (EPR) program for nearly all battery types. The official administrative rules (Chapter 173-905 WAC) became effective on January 16, 2026.

Under this framework, battery producers are legally required to join and fund a Battery Stewardship Organization (BSO) to manage the collection and recycling of batteries statewide. This moves the financial burden from local governments to the manufacturers and brands.

Does this apply to e-commerce & online sales

Yes. The law applies to any producer or retailer selling, distributing, or making available covered batteries or battery-containing products "in or into" Washington.

• Sales Ban (July 1, 2027): Starting next year, retailers (including online marketplaces) are prohibited from selling covered portable batteries unless the producer is participating in an approved state plan.

• E-commerce Responsibility: If you ship these products to Washington customers, you must ensure your brands are registered with the BSO to avoid being delisted by major marketplaces.

Who is the “producer” under Washington EPR?

Washington uses a specific hierarchy to identify the "Producer":

1. Brand Owners: The person who manufactures the battery/product under its own brand.

2. Licensees: The person who is the licensee of a brand or trademark.

3. Importers: If the brand owner has no U.S. presence, the first importer into Washington is the responsible producer.

4. Retailers: May be considered the producer if they sell "private label" brands or if the manufacturer is not registered.

Who must register for Battery EPR in Washington

• Producers: Must join and fund a BSO. By July 1, 2026, BSOs must submit their full stewardship plans to the Department of Ecology.

• Packaging Producers: Urgent! Under the Recycling Reform Act (SB 5284), producers of packaging must appoint a PRO (like the Circular Action Alliance) by January 1, 2026, and register with the Department of Ecology by March 1, 2026.

• Electronics Manufacturers: Must continue to pay annual administrative fees for the E-Cycle WA program based on their sales tiers (Tiers 1–5).

Washington EPR Thresholds & Fees

• Portable Batteries: Includes primary batteries <4.4 lbs and rechargeables <11 lbs (and <300 Wh).

• Medium-Format: Includes batteries between 4.4–25 lbs (primary) and 11–25 lbs (rechargeable).

• 2026 Admin Fees: The Department of Ecology has set a $357,634 administrative fee for 2026, which is split among BSOs.

• Electronics Tiers: For E-Cycle WA, manufacturers are assigned to tiers (e.g., Tier 1 pays $33,243; Tier 6 with <4,398 lbs sold pays $0).

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Products Covered (and Excluded)

Covered

• Portable Batteries: Household types (AA, AAA, button cells), phone, and laptop batteries.

• Medium-Format: E-bike, e-scooter, and power tool batteries.

• Battery-Containing Products: Devices with removable or non-removable batteries (though the program's primary focus is the batteries themselves).

Excluded

• Medical Devices: If they are not marketed for personal consumer use.

• Large Lead-Acid: Over 11 lbs (covered by existing vehicle battery laws).

• EV Batteries: Currently managed under Universal Waste Rules (the 2029 mandate for EV battery stewardship is still under development).

Producer Responsibility Organization (PRO/BSO)

• Batteries: Producers are expected to join a BSO (likely Call2Recycle or a similar entity) that will submit the 2026 plan.

• Packaging: The Circular Action Alliance (CAA) is the primary PRO for the new packaging rules.

EPR Registration & Reporting

• March 1, 2026: Deadline for packaging producers and their PROs to register with Ecology.

• June 1, 2026: Deadline for BSOs to pay their annual administrative fee to the state.

• July 1, 2026: Deadline for BSOs to submit the first Battery Stewardship Plan for portable batteries.

Authorized Representative

Foreign manufacturers must appoint a U.S.-based Authorized Representative to represent them within the BSO and ensure all fees and data (weight of batteries sold) are reported accurately.

Labels & Marketing Claims

• Marking Requirements: By January 1, 2028, all portable batteries must be marked with the Producer's Brand.

• Waste Iconography: By January 1, 2030, batteries must feature the "crossed-out wheeled bin" symbol and chemistry information.

• Right to Repair: As of January 1, 2026, manufacturers of consumer electronics (laptops, phones) must provide parts, tools, and schematics to consumers and independent repair shops.

Risks, Penalties & Common Mistakes

• Market Exclusion: Producers not in an approved plan by July 2027 will be legally barred from selling in Washington.

• Admin Fee Penalties: Failing to report market share data by April 1st results in the state estimating your share (often unfavorably) for fee calculations.

• Common Mistakes: Forgetting that Washington's Right to Repair now bans "parts pairing"—you cannot use software to disable third-party battery replacements.

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FAQ

• No, there is no consumer-facing fee for batteries in Washington. Costs are built into the product price by the producer.

When does the battery collection start?

• Collection of portable batteries begins July 1, 2027.

Are solar panels included?

• Not under the battery law, but they were added to Washington's Universal Waste definitions in 2026.

What if I missed the March 1st packaging deadline?

• You should register with the Circular Action Alliance immediately to mitigate late-compliance penalties.

What is California EPR Chemical

California’s framework for chemical Extended Producer Responsibility (EPR) is primarily governed by the Safer Consumer Products (SCP) regulations, often referred to as Green Chemistry laws. Managed by the California Department of Toxic Substances Control (DTSC), this program shifts the burden of chemical safety onto producers. Unlike traditional recycling-based EPR, chemical EPR focuses on the "front end" of the product lifecycle. The SCP program identifies specific product-chemical combinations, known as Priority Products, and requires manufacturers to conduct an Alternatives Analysis to justify the use of a chemical or find a safer replacement. Additionally, Senate Bill 54 and individual bans on substances like PFAS in textiles and food packaging create a broader "chemical-linked" EPR environment.

Does this apply to e-commerce & online sales

Yes. California’s chemical compliance rules apply to any entity that sells, offers for sale, or distributes products into the state. This includes distance sellers, cross-border e-commerce brands, and online marketplaces. Under the SCP regulations, if a foreign brand owner does not have a physical presence in the United States, the marketplace facilitator or the importer of record is often legally responsible for ensuring the product meets California's chemical safety and reporting standards. Marketplaces frequently mandate that sellers provide proof of compliance or face automatic delisting.

Who is the “producer” under California EPR?

The SCP regulations and related chemical bans define the responsible party through a hierarchical structure:

1. Manufacturer: The entity that manufactures the product or owns the brand name/trademark under which the product is sold.

2. Importer: If the manufacturer has no presence in the United States, the person or company that imports the product into California assumes all legal responsibilities.

3. Retailer: If neither the manufacturer nor the importer has complied, the retailer (including online marketplaces) is prohibited from selling the product and may be held liable.

Who must register for EPR Chemical in California

Companies do not register a "company profile" in the traditional sense; instead, they must register their Priority Products within the CalSAFER information system.

1. Manufacturers must submit a Priority Product Notification to the DTSC within 60 days of a product-chemical combination being listed.

2. If a product contains regulated chemicals like PFAS, manufacturers must register their intent to comply or report data through the DTSC or the EPA’s central systems (e.g., CDX for federal reporting that overlaps with CA requirements).

3. All relevant chemical disclosures are submitted to the Department of Toxic Substances Control (DTSC).

California EPR Chemical Registration Threshold

Chemical EPR in California generally does not have a "de minimis" turnover threshold. If a product is listed as a Priority Product, the following applies:

1. Volume: Even a single unit of a Priority Product sold in California triggers the requirement for notification and an Alternatives Analysis.

2. Exemptions: Exemptions are limited to products already regulated by more stringent federal laws, such as certain prescription drugs, medical devices, or food items specifically regulated by the FDA.

3. PFAS Reporting: Federal and state reporting often triggers at "any intentionally added amount," regardless of the company's annual revenue.

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Chemical Categories Covered (and Excluded)

The DTSC focuses on Chemicals of Concern that have hazardous traits like carcinogenicity or reproductive harm. Key categories include:

1. PFAS (Forever Chemicals): Banned or restricted in apparel, food packaging, and juvenile products as of 2025/2026.

2. Priority Products: Specific combinations like Nonylphenol Ethoxylates in laundry detergents or Methylene Chloride in paint strippers.

3. Microplastics: Recently proposed as Candidate Chemicals for future regulation in consumer goods.

4. Exclusions: Chemicals used in strictly industrial settings with no consumer exposure, or substances used in the manufacturing of excluded medical devices.

Producer Responsibility Organization (PRO)

Unlike packaging, California's chemical EPR does not utilize a single industry-led PRO.

1. The DTSC acts as the direct regulator and oversight body.

2. For specific materials like carpets or mattresses (which have chemical components), individual stewardship organizations like the Carpet Stewardship Council manage end-of-life chemical issues.

3. Producers generally manage chemical compliance individually through internal "Green Chemistry" departments or third-party laboratories.

EPR Chemical Registration in California

The compliance process for chemical EPR is highly technical and follows these steps:

1. Screening: Check if your product and chemical combination is listed on the DTSC Candidate Chemicals List.

2. Notification: Submit a Priority Product Notification through the CalSAFER portal if your product is listed.

3. Alternatives Analysis (AA): Conduct a scientific study to determine if a safer chemical can replace the Chemical of Concern.

4. Reporting: Submit the AA Report to the DTSC for review.

5. Regulatory Response: Comply with the DTSC’s decision, which may include product reformulation, consumer warnings, or a total sales ban.

Authorized Representative

Foreign companies (non-US based) are strongly encouraged to appoint a U.S.-based Authorized Representative.

1. This representative handles all legal submissions through the CalSAFER system.

2. They act as the primary point of contact for the DTSC during audits.

3. The representative ensures that sensitive proprietary chemical formulas (Trade Secrets) are handled according to California's strict confidentiality laws.

What Data Must Be Reported

Reporting for chemicals is significantly more granular than for packaging:

1. Chemical Identity: Specific CAS numbers and chemical names.

2. Concentration: The exact weight or percentage of the chemical within the product.

3. Exposure Data: How the consumer interacts with the product (e.g., dermal contact, inhalation).

4. Alternative Data: Technical details on potential substitute chemicals, including their hazard profiles.

First Reporting Period & EPR Reporting Deadlines

Chemical reporting follows a specific "listing" cycle rather than a single annual date for all.

1. Priority Product Notifications: Must be filed within 60 days of a chemical being added to the Priority Product list.

2. PFAS Reporting: Under federal/state overlap, a major look-back reporting period (data from 2011–2022) is set for April 13, 2026.

3. Biennial Reports: For certain hazardous waste generators or importers, the next cycle begins January 2, 2026.

Labels & Marketing Claims

California has strict labeling requirements for chemicals:

1. Proposition 65: Products containing chemicals known to cause cancer must carry a "Clear and Reasonable Warning."

2. PFAS-Free: As of 2025, apparel and textiles must not be labeled as "water-resistant" if they achieve this through regulated PFAS.

3. Ingredients Disclosure: Cleaning products must list ingredients on the label and the manufacturer's website under the Cleaning Product Right to Know Act.

EPR Eco Fees & Eco-Modulation

California does not charge a simple "per-ton" chemical fee. Instead, the "cost" is modulated by:

1. Alternatives Analysis Costs: Manufacturers of toxic products face massive administrative costs (often $50,000–$250,000 per AA).

2. DTSC Administrative Fees: For certain programs, producers pay to cover the state's cost of reviewing their specific chemical data.

3. Market Access: The ultimate "fee" for non-compliance is the loss of access to the California market.

Risks, Penalties & Common Mistakes

1. Failure to Notify: Missing the 60-day window for a Priority Product listing can lead to immediate sales bans.

2. Prop 65 Violations: Civil penalties of up to $2,500 per violation per day.

3. Incomplete AA: If an Alternatives Analysis is deemed deficient by the DTSC, the product may be forcefully removed from the market.

4. Common Mistake: Assuming that "trace amounts" of a chemical are exempt. California’s thresholds (e.g., for PFAS) are often as low as 100 ppm or "any intentionally added amount."

What E-Commerce Sellers Should Do Now

1. Audit Inventory: Review your product catalog for chemicals on the DTSC Candidate Chemicals List and the Prop 65 list.

2. Request Certifications: Demand Certificates of Compliance from suppliers, specifically for PFAS-free textiles and food packaging.

3. Monitor CalSAFER: Set up alerts for new Priority Product rulemakings that may affect your category.

4. Appoint a Representative: If you are based outside the U.S., secure a compliance partner to manage your CalSAFER submissions.

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FAQ

Is California chemical EPR mandatory for small foreign sellers?

• Yes. There is no revenue exemption for the SCP program; if your product is a Priority Product, you must comply regardless of your company's size.

Does a Prop 65 warning fulfill all chemical EPR obligations?

• No. Prop 65 is a warning law, whereas the SCP program (Chemical EPR) is a "Safer Alternatives" law that can result in your product being banned if a safer version is possible.

What happens if I sell through Amazon into California?

• Amazon requires sellers to provide chemical disclosures. If your product is a Priority Product and you have not notified the DTSC, Amazon may block your listings to avoid being held liable as the "distributor."

Are PFAS chemicals banned in all products?

• No, but they are banned in high-exposure categories like apparel, textiles, and food packaging. Most other products still require reporting and may be listed as Priority Products in the future.