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Maryland EPR Guide
Packaging and Paper Products – Producer Responsibility Plans Act (SB 901, 2025)
PRO
Circular Action Alliance (allows multiple PROs)
Agency
Maryland Department of the Environment (MDE)
Exemption
Under $2M global revenue OR less than 1 ton of covered materials (EITHER qualifies)
Fees
Fees begin 2028-2029. PRO five-year plan due Jul 2028.
Penalties
$5K-$20K (PRO); up to $250K for PRO performance failures. Producer penalties after 60-day notice.
Who is a “producer”?
Under SB 901, a “producer” is determined in the following order of responsibility:
- 1Manufacturer (if sold under manufacturer's brand or no brand)
- 2Licensee (if licensed to manufacture/sell under another's brand)
- 3Brand owner
- 4Importer of record into the US for sale in MD
- 5Person who first distributes the item in or into MD
B2B packaging is explicitly exempt in Maryland.
What's covered
Covered
- ✓Packaging (all types)
- ✓Paper products
- ✓Beverage containers (<5 liters, all materials)
- ✓Online/e-commerce sales
Not Covered / Exempt
- ✕De minimis producers (<$2M global OR <1 ton into state)
- ✕B2B packaging (distributed to commercial entity for production)
- ✕Infant formula, medical food, fortified nutritional supplements
- ✕Drugs/medical devices (FDA regulated)
- ✕EPA-regulated pesticides/FIFRA products
- ✕LPG containers designed to be refilled
- + 5 more exemptions
Key Deadlines
| Date | What's Due | Status |
|---|---|---|
| Jul 1, 2026 | PRO must register annually with MDE | UPCOMING |
| Jul 1, 2028 | PRO submits first five-year plan | FUTURE |
| Jul 1, 2028 | Each producer submits producer responsibility plan to MDE | FUTURE |
| Jul 1, 2029 | Data reporting begins | FUTURE |
| Jul 1, 2028 | Reimbursements begin (50% of cost/ton) | FUTURE |
| Jul 1, 2029 | Reimbursements increase (75% of cost/ton) | FUTURE |
| Jul 1, 2030 | Reimbursements increase (90% of cost/ton) | FUTURE |
Official Resources
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