Maryland's packaging EPR law is SB 901, enacted in 2025 and administered by the Maryland Department of the Environment. It is one of the newer programs, and it is distinctive for permitting multiple producer responsibility organizations rather than a single one. Obligated producers must register with an approved PRO by July 1, 2026, and submit a supply report covering 2025 packaging data by May 31, 2026, the first of an annual reporting cycle. The Circular Action Alliance is an approved PRO in Maryland.
Maryland is a near-term deadline state: enacted in 2025, it already has 2026 registration and reporting dates, so a producer selling into Maryland has concrete obligations this year even though the broader program is still being built. This guide covers what SB 901 requires, who is obligated, the multiple-PRO design, and the 2026 dates.
The law and the multiple-PRO design
SB 901 was enacted in 2025 and is administered by the Maryland Department of the Environment. Its distinctive feature is that it permits more than one producer responsibility organization to operate, rather than designating a single one, which can give producers a choice of PRO. The Circular Action Alliance is an approved PRO in Maryland.
Who is an obligated producer
The producer is defined through a hierarchy that generally lands on the brand owner of the covered material, shifting to the importer or distributor where there is no in-state brand owner, with small producers below the thresholds exempt. A producer selling covered packaging into Maryland needs to determine its status before the 2026 deadlines.
The 2026 deadlines
Maryland pairs a registration deadline with a reporting deadline in the same year. Obligated producers must register with an approved PRO by July 1, 2026, and submit a supply report covering 2025 packaging data by May 31, 2026, the first of an annual reporting cycle. After registration, the program moves through a needs assessment and a producer responsibility plan that set the fee structure. Confirm the current dates with the Maryland Department of the Environment.
Maryland is a this-year-deadline state despite being newly enacted. For the multistate picture, see the US packaging EPR compliance guide; to determine your status, see the US packaging EPR producer obligation assessment.
Primary sources
- Maryland SB 901 (2025): Maryland's packaging EPR law, which permits multiple producer responsibility organizations; obligated producers register in 2026.
- Circular Action Alliance: The producer responsibility organization designated or selected to run the program in most US packaging EPR states; producers register, report, and pay fees through it.