What is the Maryland packaging EPR law status in 2026?
Maryland’s Packaging and Paper Products — Producer Responsibility regulations are codified at COMAR 26.04.14 and became effective May 25, 2026. Maryland’s Department of the Environment says the rules clarify producer definitions, covered and exempt materials, registration requirements, recordkeeping, reporting and implementation timing.
What is the Maryland EPR registration deadline?
COMAR 26.04.14.07 and .10 establish the annual registration framework. Beginning July 1, 2026, the approved Producer Responsibility Organization registers with MDE and includes its participating producers. Producers that do not intend to join an approved PRO must register directly with MDE and pay the applicable annual registration fee. The regulation states that annual registration is due no later than June 30 in subsequent years.
Practical takeaway: July 1, 2026 is the start of Maryland’s producer-registration regime—not a May 31 deadline. Preserve the entity’s PRO participation or direct-registration record and recheck MDE guidance each year.
Who counts as a producer under Maryland packaging EPR?
Maryland’s adopted definition uses an entity hierarchy. Depending on the fact pattern, responsibility can move among the manufacturer, a licensed manufacturer or seller, the brand owner, an importer when the higher-priority person is not within the United States, or the first distributor when earlier categories do not apply. The regulations also address e-commerce and shipping packaging.
Maryland includes franchise-specific language. That makes the legal entity behind the brand, importer relationship or franchise structure more important than simply matching a trade name to a registry.
Unsure which Maryland entity should be registered?
Screen manufacturer, licensee, brand-owner, importer, first-distributor, franchise and remote-sale roles before assigning the compliance record.
Use the free Producer Checker →What should a Maryland EPR compliance file contain?
What happens after 2026 registration?
The rules include later plan milestones. COMAR 26.04.14.10 provides that producers complying outside the PRO must submit individual producer plans by July 1, 2028 or a later date identified by MDE, and beginning October 29, 2028 or a later MDE date, covered materials generally may not be sold or distributed without an approved responsibility plan.
Official Maryland packaging EPR sources
Related deadline and producer guides
Keep the Maryland entity, source and deadline in one record.
The Exposure Assessment maps the corporate family, producer hierarchy, official sources, evidence gaps and 90-day action plan before monitoring begins.
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