May 52026

Extended Producer Responsibility Deadlines Are Here: What Companies Complying With Packaging and Textile EPR Need to Do Now

Caleb J. Bowers, Maureen F. Gorsen and Riley Desper
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Companies preparing to comply with packaging extended producer responsibility (EPR) requirements across the United States, as well as textile producers and those in their supply chains, should update their strategies based on recent and upcoming developments across states with new programs.

States continue to advance EPR programs in 2026, with California again at the forefront with its new textiles law (SB 707). Since Sidley’s January 2026 EPR update (available here), several significant developments have occurred—most notably, final regulations under California’s packaging law (SB 54) are now in effect, triggering near-term compliance deadlines, while implementation of SB 707 is underway.

Key deadlines for these programs and other states’ packaging EPR programs are upcoming in late May, June, and July 2026, meaning that producers should act promptly to confirm applicability, determine whether they must register with the program Producer Responsibility Organization (PRO), and make required reports by the applicable deadlines.

California Packaging EPR (SB 54)

Regulations in Effect and June 1 Deadline. On May 1, 2026, the Office of Administrative Law approved and filed permanent regulations implementing SB 54, which took effect immediately. The California Department of Resources Recycling and Recovery (CalRecycle) states that producers now have until June 1, 2026 to comply by taking one of the following actions:

  • Join the approved PRO, Circular Action Alliance (CAA), and submit supply data;
  • Register with CalRecycle as an independent producer; or
  • Register with CalRecycle and apply for a small producer exemption, if eligible.

Implementation Tools and Guidance. CalRecycle has launched the Packaging Extended Producer Responsibility System (PEPRS) to support registration, reporting, and compliance. Most producers participating in CAA will likely report through CAA’s independent portal, while PEPRS provides a reporting option for independent producers (those not participating in CAA) and others who elect to self-report. CAA has also expanded its Producer Resource Center, and additional CalRecycle guidance is expected, including tools to help companies determine producer status and identify covered materials.

Upcoming Deadlines Across State EPR Programs

Producers should also be aware of May 31, 2026 reporting deadlines under several states’ packaging EPR programs administered by CAA, including:

  • Oregon and Colorado: Annual supply reports due to inform 2027 program obligations;
  • Minnesota, Maryland, and Washington: Simplified supply reports due as part of pre-program implementation; and
  • California (SB 54): Submission of 2025 packaging supply data and source reduction reporting, which will inform early program fees and future compliance obligations.

SB 54 imposes a separate June 1, 2026 registration deadline as discussed above. However, CAA previously requested data submissions by May 31, 2026 for fee-setting purposes as programs move toward full implementation. Producer-reported data will be used to calculate future fees, program targets, and compliance requirements.

SB 707 Textile EPR: Registration Open

Implementation of SB 707 is progressing following CalRecycle’s selection of Landbell USA as the PRO. For additional detail on the law and PRO selection, see Sidley’s prior post here.

Producers of covered apparel and textile products sold into California must register with the PRO by July 1, 2026. Registration is now open through Landbell’s Circul8 platform and includes a brief eligibility assessment and submission of basic company information.

For the initial 2026–2027 cycle, the PRO has announced a flat $1,000 administrative fee per producer to support program startup activities.

This post is as of the posting date stated above. Sidley Austin LLP assumes no duty to update this post or post about any subsequent developments having a bearing on this post.

Caleb J. Bowers

Los Angeles

cbowers@sidley.com

Maureen F. Gorsen

Century City

maureen.gorsen@sidley.com

Riley Desper

Washington, D.C.

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