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 runs through a single producer responsibility organization, the Circular Action Alliance, with additional PROs possible only from July 1, 2033. Producers registered with the PRO and reported simplified 2025 supply data by May 31, 2026, feeding the PRO's first annual registration with MDE on July 1, 2026 — both dates have passed.
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 single-PRO structure, and the 2026 dates.
The law and the PRO
SB 901 was enacted in 2025 and is administered by the Maryland Department of the Environment. Maryland operates through a single producer responsibility organization: MDE selected the Circular Action Alliance on October 18, 2023 under the 2023 predecessor law (Ch. 465 of 2023, Envir. § 9-2502), and reaffirmed it in 2025 as the PRO for the first five-year plan under SB 901. The design's genuinely distinctive feature sits later in the calendar: only on or after July 1, 2033 may a nonprofit ask MDE to designate an additional PRO, and then only where MDE, with the Advisory Council, finds it necessary for a specific covered-material type (Envir. § 9-2505(a)).
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 de minimis producers exempt — under one ton of covered material into the state or under $2 million in global gross revenues in the most recent fiscal year (Envir. § 9-2501(j)) — alongside exclusions for governments, 501(c)(3) and 501(c)(4) organizations, certain paper mills, qualifying single-location retailers and in-state restaurants, and alcoholic-beverage and cannabis licensees under $10 million in gross revenue (Envir. § 9-2501(p)(2)). A producer selling covered packaging into Maryland needs to determine its status before the 2026 deadlines.
The 2026 deadlines
Both 2026 dates have passed. Producers registered with the Circular Action Alliance and submitted a simplified supply report of calendar-2025 data, in broad material categories, by May 31, 2026 — a PRO-set deadline that fed the PRO's first statutory annual registration filing with MDE on July 1, 2026, listing participating producers, brands, and covered materials (Envir. § 9-2505(a)). MDE published its report of registered producers and brands in July 2026. Detailed producer reporting waits for the approved program plan; statutory annual reports to MDE begin July 1, 2029 (Envir. § 9-2509). The producer responsibility plan is due July 1, 2028 (Envir. § 9-2505(b)(1)), and cost reimbursement then ramps: at least 50 percent of cost per ton by July 1, 2028, 75 percent by July 1, 2029, and 90 percent by July 1, 2030. An in-scope producer that has not registered should contact the PRO; the annual registration cycle continues each year.
Maryland is a this-year-deadline state despite being newly enacted. For the multistate picture, see the US packaging EPR compliance guide; to determine obligated-producer status, see the US packaging EPR producer obligation assessment.
Primary sources
- Maryland SB 901 (2025), Chapter 431: Environment – Packaging and Paper Products – Producer Responsibility Plans: signed May 13, 2025, effective June 1, 2025, codified at Md. Code, Envir. §§ 9-2501 to 9-2512, building on the 2023 producer-responsibility framework (Ch. 465 of 2023). Producer registration through the PRO closed May 31, 2026; the PRO's first annual registration with MDE was filed July 1, 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.