On May 1, the California Office of Administrative Law (OAL) approved the regulations for SB 54 Plastic Pollution Prevention and Packaging Producer Responsibility Act with an effective date of May 1, 2026. As a result, initial registration and reporting deadlines are now in full effect, including a 30-day registration requirement and producer report due for 2023 baseline supply data, as well as 2025 annual supply and source reduction reports due May 31, 2026.
In addition, the second year of reporting for Colorado and Oregon, and for the first year of reporting for Maryland, Minnesota, and Washington is due by May 31, 2026.
Unlike the varied reporting deadlines in 2025, the May 31, 2026, deadline represents a critical convergence of reporting obligations across the multiple states. For California, Colorado, and Oregon, the May 31 report constitutes the annual supply report based on 2025 supply data (as well as 2023 baseline reporting for California). For Maryland, Minnesota, and Washington, the May 31 report is a simplified supply report.
State-by-State Notes
California (SB 54). SB 54's implementing regulations were approved on May 1. In addition to annual supply reporting, producers should be aware of upcoming source reduction baseline reports (due within 30 days after the effective date of the final regulations) and individual source reduction plans (due no later than August 1, 2026). If you have not completed your 2023 base line reporting to CAA yet, it and 2025 data reporting is due by May 31.
Colorado (HB 22-1355). The May 31, 2026, report covers 2025 supply data and represents the second reporting cycle for Colorado producers (the initial 2024 supply report was due July 31, 2025). Covered materials include packaging materials intended for single or short-term use and paper products such as flyers, brochures, booklets, catalogs, and magazines.
Oregon (SB 582). The May 31, 2026, annual supply report is based on 2025 supply data, with payment due in January 2027. In addition to the annual supply report, Oregon producers may submit voluntary Life Cycle Assessment ("LCA") Bonuses A, B, and C by the same May 31, 2026, deadline.
Maryland (SB 222) Preceding calendar year, less than $2,000,000 in gross global revenue; OR Sold, offered for sale, or distributed for sale less than 1 ton of packaging materials.
Minnesota (HF 3911). Minnesota's EPR law was signed in May 2024 and required producers to register with a PRO by July 1, 2025. The Minnesota Pollution Control Agency confirmed CAA's registration to implement the state's program in February 2025. The May 31, 2026, deadline is for a simplified supply report. Comprehensive stewardship plans under Minnesota's law are not due until October 1, 2028. (More information to come.)
Washington (2021 Plastic Laws). Per Washington’s law, a producer is exempt from reporting if in the preceding year, the company generated less than $5,000,000 in gross global revenue; OR sold, offered for sale, or distributed for sale less than 1 ton of packaging materials. Registration and reporting is due by May 31.
Reporting Guidance
Common pitfalls to be aware of when preparing reports include assuming producer status based on supplier name rather than the applicable state hierarchy, failing to separately inventory service packaging and shipping packaging, missing smaller packaging components such as inserts, sleeves, lids, and labels, and inadequately documenting assumptions for potential substantiation requests. In addition, keep in mind that when assessing whether a producer qualifies for simplified reporting as a Low Volume producer, the weights of all affiliate producers must be counted. If combine the weight of covered materials exceeds the Low Volume thresholds, each affiliate must report line-item weights for each covered material type—not just the total weight.
Steps To Take Now
Producers with obligations in California, Colorado, Oregon, and Minnesota should take the following steps promptly:
- Compile 2025 supply data across all relevant departments, including sales, compliance, and finance, to ensure complete and accurate reporting.
- Review the state-specific reporting workbooks and CAA’s reporting guidance to complete the workbooks for reporting to be completed by the May 31 deadline.
- Assess packaging portfolios in light of Colorado’s forthcoming eco-modulation rules and California's source reduction milestones to plan for future compliance. (Further information to be shared soon.)
Have questions or need help? Potomac Law is here to help answer your questions or assist with your reporting needs.
