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EPR Deadlines / 2027 Reporting
2027 PACKAGING EPR REPORTING

What changes after the 2026 simplified EPR reports?

Minnesota, Maryland and Washington used interim simplified reporting categories in 2026 while their programs moved through startup. That does not prove that 2027 will require SKU-level reporting. It does mean producers should expect the reporting framework to mature and should build cleaner material, entity and supply-data controls before the next cycle.

Last verified: August 10, 2026CAA + state sourcesConfirmed vs. unconfirmed clearly separated

What is confirmed about the 2026 reporting cycle?

Circular Action Alliance’s public Producer Resource Center labels the May 31, 2026 producer reports for Minnesota, Maryland and Washington as “Interim Producer Report: Simplified Reporting Categories.” The reports use calendar-year 2025 data and cover the pre-program period.

MinnesotaMay 31, 2026 · Interim simplified report
MarylandMay 31, 2026 · Interim simplified report
WashingtonMay 31, 2026 · Interim simplified report

What is not yet confirmed for 2027?

No primary source reviewed by EPRScope currently supports a blanket claim that all three states switch to SKU-level reporting in 2027. Final category structures, portal requirements and state-specific annual reporting instructions should be taken from CAA and the relevant agency when published.

“Interim” is meaningful, but it does not tell us the exact next format. A producer should therefore prepare for more mature reporting without inventing a future requirement.

Maryland: annual reporting continues

CAA’s Maryland page states that producers had to provide simplified reporting by May 31, 2026 and that producers will be required to report annually by May 31 as part of the PRO registration requirements. Maryland’s 2026 regulations also establish the program’s registration and implementation framework.

What remains to be watched is the level of material-category detail and any revised PRO guidance for the next report.

Washington: 2026 is clearly a startup year

CAA’s Washington timeline identifies May 31, 2026 as the interim state-addendum and simplified-reporting milestone and July 1, 2026 as the producer deadline to register with a PRO. The statutory program then moves through needs assessment, rulemaking and plan-development milestones before broader program implementation expected by 2030.

For 2027, producers should watch both CAA reporting instructions and Washington Ecology rulemaking rather than assuming the 2026 simplified template will remain unchanged.

Minnesota: reporting is developing alongside rulemaking

Minnesota’s May 2026 submission was also an interim simplified report. The MPCA continues rulemaking under the Packaging Waste and Cost Reduction Act, including work that can affect definitions, exemptions, stewardship-plan provisions and annual reporting. That makes version-controlled source tracking especially important.

What producers should prepare now for the 2027 cycle

Clean entity ownership. Know which legal entity is the producer for each state before reconciling material data.
State-level supply totals. Maintain covered-material quantities by state and reporting year.
Material-category mapping. Keep an internal mapping from packaging/material records to current CAA/state categories so taxonomy changes can be handled without rebuilding the dataset.
Exemption support. Preserve revenue and tonnage calculations separately for each entity and state.
Source/version history. Save the reporting guidance used for each submission so a later category change can be reconstructed.
Portal receipts. Keep confirmation of submission, amendments and any producer/PRO correspondence.

Why reporting maturity matters to multi-entity companies

The more granular reporting becomes, the more costly it is to discover late that a parent, importer, brand owner or operating subsidiary was treated as the wrong producer. Entity resolution belongs upstream of material reporting, not after the filing data is assembled.

Official and PRO sources

CAA — 2026 producer-report planning tableCAA — Producer reporting resourcesCAA — Maryland reporting timelineCAA — Washington reporting timelineMinnesota MPCA — PWCRA rulemaking

Related reporting resources

EPR deadline calendar

Track producer reporting dates as the next cycle is published.

Missed a report?

See the corrective workflow if a producer misses an operational deadline.

Prepare the data architecture before the reporting template changes.

EPRScope keeps legal-entity responsibility, source versions, reporting cycles and open actions connected while the state programs mature.

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