Maryland packaging and paper producer responsibility in 2026.

Current Maryland EPR status

Maryland’s Packaging and Paper Products — Producer Responsibility regulations, COMAR 26.04.14, became effective May 25, 2026. The Maryland Department of Environment states that the regulations clarify which entities meet the definition of producer, identify covered and exempt materials, establish registration requirements and set implementation timelines.

Producer registration starts in 2026

COMAR 26.04.14.10 provides that, beginning July 1, 2026 and annually thereafter, the approved Producer Responsibility Organization must register with the Department. Producers that do not intend to join an approved PRO must also file an annual registration form and pay the applicable registration fee.

The regulations also provide later implementation milestones, including responsibility-plan requirements that become relevant in 2028.

Maryland’s producer definition is entity-specific

The adopted definition follows a hierarchy that can identify the manufacturer, a licensed manufacturer/seller, the brand owner, an importer when earlier persons are not within the United States, or the first distributor when the earlier categories do not apply. The regulation also addresses e-commerce and shipping packaging.

For franchise structures, Maryland’s regulations include additional language assigning producer status to the franchisor in specified circumstances. This is another reason a company should not infer producer identity from the marketing brand alone.

What Maryland teams should preserve

Implementation continues beyond registration

Maryland’s regulations include future plan and compliance milestones. That means 2026 registration should be treated as the beginning of a recurring compliance record, not the end of the analysis.

Official Maryland sources

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