Five EPR dates, five confidence levels
Five dates keep showing up in decks. Only two are mandates. Each date below carries a different legal status. Mixing an operational window with a statutory deadline misleads leadership and wastes staff time.
Here is a factual breakdown of the key dates currently governing state packaging compliance, alongside their verified regulatory status:
The five key dates
| Date | Event & Description | Regulatory Status |
|---|---|---|
| Oct 4, 2026 | California SB 343 recyclability-labeling restrictions keyed to packaging manufactured after this date. | Statutory date, but enforcement is currently preliminarily enjoined (July 14, 2026). Monitor docket updates. |
| Oct 13, 2026 | Circular Action Alliance scheduled to submit its final California program plan to CalRecycle. Final 2027 fee schedules expected. | Scheduled milestone; plan remains subject to formal agency review and approval. |
| Jan 1, 2027 | California PRC §42051(b) sales restrictions take effect upon plan approval or Jan 1, 2027, whichever is sooner, subject to approved PRO participation. | Statutory text; individual producer status requires legal review. |
| Jan 2027 | Oregon and Colorado expected to issue 2027 annual producer fee invoices, following prior annual cycles. | Operational expectation based on historical administrative patterns. |
| May 31, 2027 | Anticipated annual CAA supply reporting window for prior-year packaging data across active reporting programs. | Reconfirm per state and report type once official CAA calendars are published. |
Two important administrative nuances should be noted: First, while May 31 was used by Circular Action Alliance in 2026 as a common reporting date across six state programs, it represents a PRO operational deadline rather than a uniform statutory deadline. Second, Maine operates on an independent statutory schedule (reporting, invoicing, and reimbursement occurring across May through October) and remains on an extended timeline while stewardship organization procurement is finalized.
Maintaining date discipline in operational planning
When presenting compliance timelines to executive leadership, distinguish clearly between confirmed statutory mandates and operational estimates. Rechecking primary agency and PRO sources before scheduling major packaging transitions takes only a few minutes, but prevents costly planning errors.
Sources (primary)
- CAA Producer Resource Center (2026 report/invoice tables: May 31 reports, OR/CO January invoices, CA August early-fee invoice) — https://circularactionalliance.org/producer-resource-center — retrieved 2026-09-22
- CAA California timeline (Nov 15 2025 data due; June 15 2026 plan; Oct 13 2026 final; Jan 1 2027 program start) — https://circularactionalliance.org/california — retrieved 2026-09-22
- PRC §42051 (sales restriction text) — https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=PRC§ionNum=42051 — retrieved 2026-09-22
- CalRecycle SB 54 page (June 15 2026 plan milestone; May 1 2026 regs) — https://calrecycle.ca.gov/packaging/packaging-epr/ — retrieved 2026-09-22
- CAA program-plan public comment page (June 15–Aug 14 2026 window) — https://circularactionalliance.org/ca/program-plan-public-comment — retrieved 2026-09-22
- Maine DEP stewardship program (contrast-case annual schedule) — https://www.maine.gov/dep/waste/recycle/epr.html — retrieved 2026-09-22
- CalRecycle recycling-labels page (Oct 4 manufacture-date trigger) — https://calrecycle.ca.gov/wcs/recyclinglabels/ — retrieved 2026-09-22
Data and compliance support only. Not legal advice. Recheck CAA state pages and the cited statutes before relying. Dates move. Planning against a calendar: request a fit check at alex@producerledger.com.