For finance teams
Packaging EPR is a new cost line. We make it a predictable one.
Packaging EPR (extended producer responsibility) fees are set per material and billed state by state. In the programs already charging fees, the bill is based on packaging data from two years earlier, and rates can move sharply from one year to the next. We give your controller or CFO a fee forecast by state and material, a calendar of every invoice and filing, and the documentation behind every number.
Why these fees are hard to budget
They lag by two years. In Oregon and Colorado, 2026 fees are based on 2024 packaging data, and 2027 fees on 2025 data. A packaging change made today shows up in the bill about two years later.
Rates move, in both directions. Of the 60 Oregon rate categories in both the 2026 and 2027 schedules, 58 fell in 2027, many by half or more, mainly because the program is returning about $80 million of reserves through lower rates. Small-format plastic rose, from 28¢ to 78¢ (CAA's 2026 Oregon schedule, page 2; 2027 schedule, page 3). In Colorado, 44 of 61 rates rose in 2027 (CAA's 2027 Colorado schedule, pages 2 and 3). In our worked example, the same packaging costs more in Colorado in 2027 than in 2026.
Every state is different. Each program sets its own material categories, rates, bonuses and surcharges. California adds a second charge on plastic from 2027, to fund a $500 million-a-year mitigation fund.
The data sits outside finance. The fee depends on the material and weight of every packaging component, which usually lives with suppliers and co-packers, not in your ERP.
For the mechanics, read How EPR fees are calculated.
What finance gets
- A fee forecast by state and material, ready for next year's accrual
- A calendar of every invoice, report and registration deadline
- The packaging data and calculations behind every filing
- Packaging changes that would lower the fee, with the estimated saving
- A written record of where you're obligated, and why
The billing cycle
When each state bills, and what the bill is based on.
Where the seven programs stand today. CAA is Circular Action Alliance, the main producer responsibility organization (PRO) in every state except Maine. A PRO is the nonprofit that runs a state's program and bills the companies in it.
| State | What's billed | When | Based on |
|---|---|---|---|
| Oregon | Program fees, invoiced by CAA | January and July | Two years earlier (2026 fees use 2024 data) |
| Colorado | Dues, invoiced by CAA | January and July | Two years earlier (2027 dues use 2025 data) |
| California | Program fees plus the Plastic Pollution Mitigation Fund | One-time early fee in August 2026. From 2027, January and July, plus a separate January invoice for the mitigation fund | Preliminary 2027 schedule published October 1, 2026 |
| Maine | Fees, once the state's contract with a program operator starts | Report May 31, invoice July 1, pay September 1 | On hold until a contract takes effect |
| Minnesota, Maryland, Washington | Membership and simplified reporting now; fees later | MN: PRO membership since July 1, 2025; MD and WA: from July 1, 2026 | MN fees from 2029; MD before its 2028 plan; WA from 2030 |
Summarized from each program's published rules and schedules; see the state guides for sources. General information, not legal or accounting advice.
Know the number before the invoice arrives.
Start with a free, written answer on where you're obligated.