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Maine EPR Guide

Stewardship Program for Packaging (LD 1541, 2021)

Pre-Launch — SO Selection
PRO
Stewardship Organization (SO) — to be selected via RFP
Agency
Maine Department of Environmental Protection (DEP)
Exemption
Under $2M global OR <1 ton OR >50% closeout/salvage revenue OR <15 tons perishable food packaging
Fees
Start-up fees due ~Sept 2026. No fee schedule has been proposed yet. SO to be selected via RFP.
Penalties
TBD — not yet included in regulations

Who is a “producer”?

Under LD 1541, a “producer” is determined in the following order of responsibility:

  1. 1Person with legal ownership of the brand of a product sold in packaging in or into ME
  2. 2Sole entity that imports into ME a product in packaging branded by a person with no US physical presence
  3. 3Person who adds packaging material to another producer's product for direct consumer distribution

What's covered

Covered

  • ✓Packaging material only (NOT printed paper)

Not Covered / Exempt

  • ✕De minimis producers (<$2M global OR <1 ton OR >50% salvage/closeout revenue OR <15 tons perishable food)
  • ✕Long-term storage/protection of durable products (5+ year lifespan)
  • ✕Beverage containers under Maine bottle bill
  • ✕Architectural paint containers (80%+ recycling rate)
  • ✕Materials excluded by DEP rule

Key Deadlines

DateWhat's DueStatus
Feb 1, 2026Maine DEP releases RFP for SO selectionUPCOMING
Apr 1, 2026DEP contracts with SOUPCOMING
May 31, 2026Producers register with SO and report dataUPCOMING
Sep 1, 2026Producer start-up fees due (180 days after SO contract)UPCOMING
Oct 1, 2027SO remits first payments to municipalitiesFUTURE

Special Exemptions

Maine has more generous exemption criteria than other states. A producer is exempt if ANY of the following apply:

  • ✓Less than $2,000,000 in global gross annual revenue
  • ✓Less than 1 ton of packaging material into Maine
  • ✓More than 50% of total gross revenue from insurance salvages, closeouts, bankruptcies, liquidations
  • ✓Perishable food producers with less than 15 tons of total packaging material

Official Resources

Maine Department of Environmental Protection (DEP)maine.gov/dep/waste/recycle/epr.htmlCAA Maine Portalcircularactionalliance.org/circular-action-alliance-maine

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