Guide · published 2026-07-17

OR, CO & CA packaging EPR in mid-2026: where producers actually stand

The deadlines most 2026 planning was built around are behind us. What matters now is report status, substantiation, and August.

The 2026 reporting picture (and why “done” is the wrong question)

Circular Action Alliance's 2026 producer table put the big three annual supply reports — Oregon, Colorado, and California, all on CY2025 data — due May 31, 2026. California stacked two more on the same date: the CY2023 baseline producer report and the annual source-reduction report. Minnesota, Maryland, and Washington took simplified interim reports, also due May 31.

Program2026 reportData yearDue
OregonAnnual supply reportCY2025May 31, 2026 (past)
ColoradoAnnual supply reportCY2025May 31, 2026 (past)
CaliforniaAnnual supply report; baseline producer report; annual source-reduction reportCY2025 / CY2023 / CY2025May 31, 2026 (past)
CaliforniaIndividual source-reduction planAug 1, 2026
MN / MD / WAInterim producer report (simplified categories)CY2025May 31, 2026 (past)

With May 31 behind us, the operative questions are status questions: was each report submitted, was it complete, is anything flagged for correction, and can you substantiate the numbers if the program operator asks? That is a different project than filing on time, and pretending otherwise wastes the summer.

Source: CAA Producer Resource Center (checked 2026-07-16, re-checked 2026-07-17).

Money already in motion

  • Oregon: fee obligations began July 1, 2025; 2026 program fees invoiced January 2026 in two 50% installments, driven by the CY2024 supply report.
  • Colorado: dues began January 2026; invoiced January 2026 in two 50% installments, driven by the CY2024 report.
  • California: program fees start January 2027, but early fees are expected to be invoiced around August 2026 — driven by the CY2025 annual supply report. The numbers you filed (or should have filed) on May 31 become an invoice.

Source: CAA Producer Resource Center 2026 fees/dues table (re-checked 2026-07-17).

August 1 is fourteen days out from this page's publication date: California's individual source-reduction plan deadline. If that plan is not drafted, that is this week's problem, not a Q4 problem.

Standing this up without heroics

Our approach is a data close, borrowed from accounting: reconcile what was reported against what your sales and packaging records actually support, document the gaps, and produce a substantiation pack a program operator or auditor can follow. The component-level data guide shows the shape of the underlying records; the Status & Exposure Scanner gives you a first read in the browser — nothing uploads.

Honesty note. PackClose is independent of CAA and every state program. A late or deficient report is a fact to establish and address with the program operator — we do not claim that remediation cures noncompliance, and nothing here is legal advice.