Maryland’s finalized Extended Producer Responsibility regulations for packaging and paper products mark an important shift for manufacturers that sell, distribute, import, or place covered materials into the Maryland market.
The first set of rules became effective on May 25, 2026, and while they focus mainly on registration and early reporting, manufacturers should not view them as a simple administrative step. These regulations are part of a broader packaging compliance program that will continue to develop over the next several years.
Here’s what you need to know.
What Maryland Finalized
The Maryland Department of the Environment has adopted our state’s first finalized Extended Producer Responsibility regulations, which apply to packaging and paper products.
At this stage, the rules focus mainly on:
- Producer registration
- Early reporting requirements
- Covered material categories
- Recordkeeping expectations
- Information needed by the state and the Producer Responsibility Organization
Additional rulemaking may still follow to address full reporting categories, fee structures, producer responsibility plan requirements, covered material details, and other program implementation issues. Manufacturers should expect the program to become more detailed over time.
Why This Matters Now for Manufacturers
EPR shifts responsibility for packaging management onto producers. In practice, that means manufacturers may need to:
- Report on packaging materials placed in Maryland
- Help fund recycling or material management systems
Packaging decisions once owned by procurement or operations now have compliance and financial implications. A corrugated box, plastic film, paper insert, or branded carton may need to be identified, classified, weighed, and reported.
Manufacturer Impact: Operational, Financial, and Compliance Pressures
Maryland’s EPR regulations may create pressure for manufacturers in three main areas: operations, finance, and compliance.
From an operational standpoint, manufacturers may need better systems for tracking packaging materials. This can include material type, material weight, product line, brand, supplier information, and sales or distribution in Maryland. For some companies, this information may already exist in different systems. For others, it may be incomplete, inconsistent, or stored across multiple teams.
The challenge is not only collecting data. It is collecting the right data in a format that can support reporting and future review.
These burdens are real, especially for small and mid-sized manufacturers with lean teams. But early preparation can reduce confusion and help companies make better decisions as the program develops.
Key Maryland EPR Deadlines to Track
Manufacturers should pay close attention to the program timeline. Some deadlines are near-term reporting and registration milestones, while others relate to the broader program structure.
Deadline
What’s Due
June 1, 2026
Simplified supply report to the Circular Action Alliance (CAA) (covers CY 2025 Maryland data)
July 1, 2026
CAA registers with Maryland; direct filers register with the state
July 1, 2028
Producer responsibility plans due
Oct 29, 2028
No sales of covered materials in Maryland without an approved plan
This timeline gives manufacturers some runway, but it should not create a false sense of comfort. The companies that are best prepared in 2028 will likely be the ones that start building reliable packaging data and internal processes now.
How Maryland MEP Is Preparing to Support Manufacturers
Maryland MEP recognizes that manufacturers are being asked to respond to a complex and evolving regulatory environment. As Maryland’s EPR program develops, Maryland MEP is working to identify and align resources to help manufacturers better understand what the rules may mean for their operations and how they can prepare in a practical way.
This support is especially important for small and mid-sized manufacturers that may not have dedicated compliance teams or internal EPR expertise. Many manufacturers are already managing workforce challenges, supply chain pressure, cost increases, and customer demands. New packaging regulations add another layer of complexity.
Some key questions that Maryland manufacturers may need to consider:
- Does the regulation potentially apply to our company?
- What packaging and paper product data do we need to gather?
- Which teams should be involved internally?
- How should we document assumptions or data gaps?
- What deadlines should we be tracking?
- Where might we need additional technical, legal, or compliance guidance?
What Manufacturers Should Do Next
- Does your company place covered packaging in Maryland?
- Build a packaging inventory: Material type, weight, format, brand, supplier. Don’t overlook inserts, wraps, or food-related packaging.
- Gather Maryland-specific supply data: Allocate sales data to Maryland. Document your method and any estimates.
- Assign internal ownership: Who tracks deadlines? Who coordinates with CAA? This works best as a cross-functional process.
- Monitor future updates: From Maryland regulators, CAA, and Maryland MEP.
Turning EPR Uncertainty Into a Practical Plan
Maryland’s finalized EPR regulations bring new responsibilities for manufacturers, but early preparation makes compliance manageable. Maryland MEP is developing resources to help manufacturers navigate the regulations and plan practical next steps as the program evolves.
