When did packaging EPR fees actually start?
Fee obligations began July 1, 2025
CAA identifies Oregon as the first state with producer fee obligations. Its public 2026 planning table shows 2026 program fees invoiced beginning in January 2026 in two 50% installments.
Dues began January 2026
CAA and CDPHE confirm Colorado producer dues began in January 2026. CAA’s 2026 planning table also describes two 50% installments based on prior supply reporting.
Early fees in August 2026; statutory program fees in 2027
CAA’s public planning table identifies a one-installment California “Early Fee” invoice in August 2026. CAA separately states that California fee obligations begin in January 2027.
Why individual producer costs vary so much
Oregon EPR costs
CAA says Oregon’s 2026 producer fee calculation uses the company’s calendar-year 2024 Oregon supply data and the CAA 2026 Oregon Producer Fee Rate Schedule. That rate schedule is available through the Producer Portal. The public resource center confirms the 2026 payment is split into two 50% installments.
That means an accurate Oregon budget requires the producer’s actual covered-material data and current CAA rate schedule. A generic per-company estimate without those inputs can be materially misleading.
Colorado EPR costs
Colorado dues likewise depend on the producer’s supply data and CAA’s Colorado due-rate schedule. CDPHE says producers must pay producer-responsibility dues annually, beginning in January 2026. CAA’s public 2026 planning table ties those dues to calendar-year 2024 Colorado supply data and shows two 50% installments.
California SB 54 costs
California has two cost concepts that should not be blended together. CAA’s public 2026 planning table lists an August 2026 early-fee installment based on calendar-year 2025 supply data. Separately, CAA says California’s normal fee obligations begin in January 2027.
California law also establishes a broader Plastic Pollution Mitigation Fund funding requirement: CalRecycle states producers collectively must fund $5 billion over ten years—$500 million per year beginning in 2027. That is a statewide statutory funding requirement, not a $500 million bill to any individual producer.
Do not use statewide program cost as a company quote. Your producer invoice depends on the applicable fee schedule and your reported covered-material profile.
What data do you need to estimate your EPR cost?
- Identify the obligated legal entity in each state.
- Confirm whether an exemption applies.
- Pull the applicable reporting-year supply data.
- Map materials into the current state/PRO reporting categories.
- Use the current approved or published fee-rate schedule for that fee year.
- Separate base fees from eco-modulation, special assessments and startup/early fees.
- Preserve the source and fee-schedule version used for the estimate.
Official and PRO fee sources
Related high-intent guides
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