An Expert Review of Packaging Extended Producer Responsibility (EPR) in the U.S. and Canada
The shift from municipal waste management to Extended Producer Responsibility (EPR) across North America accelerated dramatically in 2025. For producers operating internationally, this period has been defined by complexity, rapid deadlines, and the challenging reality of managing a patchwork of state and province level programs.
As the EPR consulting division of H2 Compliance, CGlobal has been on the front lines, helping clients manage a wave of initial registration, data reporting, and fee payment obligations. Looking ahead to 2026, the focus in many jurisdictions shifts from policy formation to full operational execution.
Here is CGlobal’s analysis of the 2025 landscape, the key challenges faced, and what manufacturers, importers, and brand owners should anticipate in 2026.
The United States Breakdown: The Seven-State Patchwork
2025 was the year several U.S. EPR mandates moved from legislative theory to binding compliance. With seven states (Maine, Oregon, Colorado, California, Minnesota, Maryland, and Washington) now having packaging EPR laws, the focus has started to shift to implementation. Work is underway to work out any kinks in the process, and producers need to do their best to comply or risk penalties for non-compliance in the future.
2025 Recap: Deadlines, Data, and Friction
The defining characteristics of 2025 in the U.S. were the appointment of Producer Responsibility Organizations (PROs) for packaging EPR, the first wave of data reporting, and the first fees.
- Mandatory PRO Membership & Data: Oregon and Colorado, in particular, saw their initial sales restrictions (for non-compliant producers) take effect in 2025. Producers in these states, and later in California, were required to join the state-approved PRO (Circular Action Alliance, in most cases) and submit detailed packaging data reports.
- Regulatory Roadblocks (California SB 54): California, with its groundbreaking Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54), faced significant regulatory friction. Draft implementation regulations underwent multiple revisions, forcing CalRecycle. This volatility highlights the primary challenge in the U.S.: the lack of a standardized federal approach forces brands to constantly monitor state-by-state regulatory evolution.
- The Narrowing Scope in Maine: Maine, the first state to pass a packaging EPR law, amended its legislation in 2025, narrowing the scope to focus specifically on consumer packaging (excluding business-to-business/industrial components). This change impacts reporting calculations and cost exposure for many producers.
- An increase in states mandating statewide recycling assessments: Several states (Hawaii, Illinois, and Rhode Island) have taken the pre EPR law step of requiring a statewide assessment of recycling, or in the case of Illinois the establishment of a recycling advisory council, to better understand the needs and capabilities in the state. Maryland required such an assessment in 2023, which lead directly to their 2025 packaging EPR law.
Interested in tracking critical EPR-related bills? Sign up for our Legislative Compass today!
2026 Outlook: Fees, Full Implementation, and Expanded or New Streams
2026 will be defined by the first major fee payment cycles and the expansion of EPR.
| State | 2026 Key Compliance Event | Impact on Producers |
| California | January 1, 2027: PRO fees due | Direct financial impact based on reporting data |
| Colorado | January 1, 2026: PRO fees are due | Direct financial impact based on 2024 reporting data |
| Maine | May 31,2026: Producers must register and report estimated 2025 packaging data September 2026: First EPR fee due | First compliance deadline that directly impacts packaging suppliers based on material volume |
| Maryland | July 1, 2026: Deadline for producers to register with the PRO | Marks the official entry point for producer obligations in a new, major East Coast market |
| Minnesota | TBD | Producers should already be registered |
| Oregon | May 31, 2026: Report due | The start of the second year of Oregon’s packaging EPR program |
| Washington | July 1, 2026: Deadline for producers to register with the PRO | Marks the final West Coast state to impose packaging EPR producer obligations |
Emerging EPR Streams in the U.S.
The U.S. EPR landscape is expanding and diversifying beyond packaging:
- Textiles: California’s SB 707 (Textiles) mandates that prospective Producer Responsibility Organizations (PROs) submit their compliance plans to the state by January 1, 2026. The approval of the chosen PRO will set the stage for detailed fee structures and collection targets in the coming years. New York and Washington are closely monitoring California’s progress, suggesting a multi-state textile obligation is on the horizon.
- Batteries: Following the lead of Nebraska’s Safe Battery Collection and Recycling Act (enacted in 2025), 2026 will likely see intense rulemaking activity in several states. Furthermore, the U.S. EPA has said it will release a detailed report in early 2026 outlining a framework for a national battery EPR system, potentially harmonizing disparate state laws.
- Right to Repair (RtoR): Although not EPR, Right to Repair laws do create obligations for producers. Such EPR adjacent laws are growing in popularity and number. Only Quebec has a RtoR law in Canada, but 8 states in the U.S. now have RtoR laws (California, Colorado, Connecticut, Minnesota, New York, Oregon, Texas, and Washington), and several states have RtoR bills under review for possible introduction in 2026.
Canada Breakdown: The Final Transition to Full Producer Responsibility
While the U.S. has been building its framework, Canada has been executing the final stages of its long-planned provincial transitions. 2025 saw significant momentum with programs rolling out in Alberta and Quebec, and Nova Scotia joining the full EPR model in December.
2026 Outlook: Ontario’s Standardization and Harmonization
The most crucial events for Canadian EPR in 2026 are the completion of Ontario’s and Quebec’s Blue Box transition.
- Ontario Standardization (January 1, 2026): Effective January 1, 2026, the shift to full EPR for Blue Box materials will be complete. This change standardizes the list of accepted recyclable materials across the entire province, finally removing the municipal patchwork that complicated compliance for decades. Producers will bear the full financial and operational responsibility for the province’s massive residential recycling system.
- New Brunswick Regulatory Change: New regulations take effect on January 1, 2026, formalizing the producer hierarchy and expanding the list of designated materials, requiring a full refresh of compliance protocols for producers operating in the Atlantic region.
- Quebec Standardization: By the end of 2025, there will be a unified Blue Box system, covering all waste generators (residential, public, institutional), funded and managed by Producers.
Canada’s full transition to EPR is reaching its final stages. Some provinces are starting to focus on eco-design and eco-modulation, which would make your brand’s financial liability directly tied to your packaging choices.
Looking for more information on essential reporting & upcoming deadlines for 2025 and 2026 across Canada? Access our [Free] On-Demand webinar, HERE, with a special guest speaker from Deloitte.
The Path Forward: Strategy and Preparedness
The key takeaway from 2025 is that the days of delaying compliance without consequences are over. With fees due and enforcement commencing in key jurisdictions, a reactive approach is no longer sustainable.
The greatest challenge for 2026 is lack of harmonization. Producers must manage disparate deadlines, conflicting material definitions, and different fee structures across a growing list of U.S. states and Canadian provinces.
Secure Your 2026 Compliance
The window for building internal compliance infrastructure is closing. Don’t wait for the next set of deadlines to hit your inbox.
CGlobal specializes in converting the fragmented North American regulatory complexity into a single, unified compliance strategy. Our services provide:
- Gap Analysis: Identifying your current exposure across all seven U.S. states, and Canadian provinces.
- Data Aggregation: Streamlining data collection (material type, weight, sales volume) required for reporting across multiple jurisdictions.
Ready to streamline your North American EPR compliance? Contact CGlobal today for a tailored consultation and ensure your strategy is built for the complexity of 2026.
Published December 15th, 2025
This article was generated with the assistance of Artificial Intelligence.