EPR Deep Dive: Maryland
Background
On May 13, 2025, Maryland Governor Wes Moore signed Senate Bill 901 into law, making Maryland the sixth state in the U.S. to establish a comprehensive Extended Producer Responsibility (EPR) program for packaging and paper products. The law takes effect on July 1, 2025, and will be administered by the Maryland Department of the Environment (MDE), shifting the financial and operational responsibility of recycling from local governments to producers.
Get more critical information from our EPR bulletin.
What Companies Are Affected?
Producers are any company that places a product containing packaging onto the Maryland market. That includes:
Manufacturers
Brand owners
US importers
Distributors
For e-commerce, the entity packing the product may also be deemed the producer.
A de minimis exemption applies to those introducing under 1 ton/year of covered materials in Maryland or less than US $2 million in global gross revenue, making it the lowest revenue threshold in U.S. EPR programs.
Key Deadlines
April 1, 2027: Submission of initial Producer Responsibility Plans.
July 1, 2028: PRO must submit a 5-year plan and reimburse local governments for 50% of end-of-life material costs.
July 1, 2029: Reimbursement rates rise to 75% and producers submit reports to demonstrate compliance.
July 1, 2030: Reimbursement rate rises to 90%.
Noncompliance Penalties
Producers found to be noncompliant with Maryland’s EPR program may face civil penalties up to $20,000 per violation.
Maryland EPR Program Requirements
The goal of Maryland’s EPR program is to reduce waste sent to landfills, lower greenhouse gas emissions, and increase recycling to over 50%. This is expected to generate around $200 million in material value and support 2,000 jobs without the state having to raise taxes. To do this, the Maryland Department of the Environment will:
Collect packaging and paper materials reports from producers.
Establish eco-modulated fees to incentivize packaging that supports reduction, reuse, composting, or recycling.
Use these collected funds to upgrade infrastructure, reimburse local governments for processing and collection, monitor performance, and provide outreach and education.
Producers will be responsible for reporting on the weight and recyclability of their materials, in order to reach a 90% reimbursement rate for local governments by 2030.
More EPR Deep Dives
California | Colorado | Maine | Minnesota | Oregon | Washington
Maryland EPR Best Practices
Complying with Maryland’s EPR law will be a significant undertaking for obligated producers, so it’s essential to get started early. Here are 5 best practices to ensure compliance.
Determine whether your company qualifies as a producer and find out if you meet the de minimis exemption threshold.
Identify which of your packaging types and paper products qualify as covered materials.
Start building internal material data systems and tracking packaging and paper volumes.
Stay informed about registration with Circular Action Alliance.
Start integrating eco-design principles to minimize your PRO fees.
Maryland EPR Support from Snaplinc
Maryland’s EPR reporting obligations are intimidating, but there’s time to prepare before you need to register with Circular Action Alliance. Our team of EPR experts can guide you through the process of EPR compliance, from registration to reporting. Our streamlined process makes it possible to achieve compliance while positioning your business to leverage the benefits of more sustainable packaging.
Set up a meeting with us today to your EPR compliance needs.