Materials covered
- Plastic, glass, metal, paper packaging
- Paper products
- Cosmetic primary and secondary packaging
Packaging EPRMD
Maryland packaging producer responsibility
SB 901 — Packaging and Paper Products Producer Responsibility Plans (2025, ch. 431)
Maryland's Packaging and Paper Products – Producer Responsibility Plans Act (SB 901, 2025 chapter 431) was signed May 13, 2025 and took effect June 1, 2025. It requires producers of packaging and paper products to pay fees that help cover the cost of recycling them. Circular Action Alliance is the approved Producer Responsibility Organization, producers had to register by brand and covered material by July 1, 2026, and from October 29, 2028 (or a later date MDE sets) a producer outside an approved plan may not sell covered materials in Maryland.
Last updated:
- State agency
- Maryland Department of the Environment (MDE)
- Producer Responsibility Organization
- Circular Action Alliance (CAA)
Who is a producer in Maryland?
Generally the brand owner of the product placed in covered packaging. Small producers below the law's thresholds are exempt; check the current thresholds with MDE.
Producer obligations
- Register with Circular Action Alliance, the approved PRO, by brand and covered material (due July 1, 2026)
- Submit the interim producer report to CAA; the 2026 report, on calendar-year 2025 data, was due May 31, 2026
- Pay fees to the PRO as the approved plan sets them
- From October 29, 2028 (or a later date MDE sets), sell covered materials only under an approved plan
Compliance timeline
- Active
Statute signed
SB 901 became 2025 chapter 431, effective June 1, 2025.
- Active
Regulations adopted
MDE's registration regulations (COMAR 26.04.14) were adopted.
- Reporting begins
Interim producer report
Producers' 2026 interim report to CAA in the simplified reporting categories, on calendar-year 2025 data.
- Active
Producer registration
Producers had to register with the PRO by brand and by covered material.
- Upcoming
Producer responsibility plan due
The PRO's producer responsibility plan is due to MDE.
- Upcoming
Sales require an approved plan
A producer outside an approved plan may not sell covered materials in Maryland (or from a later date MDE sets).
How Cosmetica helps
Cosmetica coverage for Maryland
Cosmetica builds Maryland's CAA interim producer report workbook, in the simplified reporting categories, from your packaging BOMs and per-state sales, and marks every packaging weight that is an estimate. It does not calculate fees.
Primary sources
- MDE — Producer Responsibility
- SB 901 (2025) — Chapter 431
- MDE COMAR 26.04.14 Compliance Guide (September 2026)
EPR statutes and rules are evolving. Verify the latest dates, fee schedules, and de minimis thresholds with the state agency before relying on this summary for compliance decisions.