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Maryland Packaging EPR Compliance Guide — 2026

Everything brands need to know about Packaging and Paper Products Producer Responsibility (SB 901), including deadlines, data requirements, material categories, exemptions, and reporting preparation.

Check your Maryland readiness
Key Facts
LawSB 901 — Packaging and Paper Products Producer Responsibility
AdministratorMaryland Department of the Environment
PROTBD
EffectiveSigned May 2025
RegistrationPRO registration is expected by July 1, 2026.
ReportingProducer plans are due July 1, 2028.
ExemptionLess than 1 ton into Maryland or less than $2M in global gross revenue.
Who Needs to Comply

A producer may include the brand owner, licensee, importer, or seller responsible for packaged products entering Maryland.

Packaging and paper products sold into Maryland.

Small producer note: Less than 1 ton into Maryland or less than $2M in global gross revenue.

What Data You Need
  • SKU-level sales into the state
  • Packaging BOMs for covered SKUs
  • Component material categories
  • Component weights in grams
  • PCR and recycled content
  • Recyclability and evidence files

Key Deadlines

PRO registration
July 1, 2026
Producer plans due
July 1, 2028

Material Categories for Maryland

These are common packaging categories brands should be ready to classify and report. Always follow final state and PRO instructions.

MaterialClassMaryland note
PETPlasticCommon priority material for this state.
HDPEPlasticCommon priority material for this state.
PVCPlasticReport PVC separately when identified as vinyl, PVC, or resin code #3.
LDPEPlasticReport as LDPE or #4 plastic when supplier documents state low-density polyethylene.
PPPlasticReport as PP or #5 plastic, especially for closures and small components.
PSPlasticReport rigid PS separately from EPS foam where programs distinguish the two.
EPSPlasticReport foam EPS separately when required; do not combine with rigid polystyrene unless the report format instructs it.
Other PlasticPlasticUse only when the resin is unknown or explicitly categorized as other/#7 plastic.
Multi-layer PlasticPlasticUse when the package includes multiple plastic layers or barrier materials that prevent single-resin classification.
Small-format PlasticPlasticUse where reporting programs separate small-format plastics from regular resin categories.
Clear GlassGlassReport clear/flint glass separately when color categories are required.
Brown GlassGlassUse brown/amber glass category when documents call out amber, brown, or UV-protective glass.

How to Report

  1. 1Estimate Maryland units and packaging tonnage.
  2. 2Check small producer exemption thresholds.
  3. 3Collect supplier specs for top-selling SKUs first.
  4. 4Prepare for registration and future producer plan data needs.
Common Mistakes
  • • Missing the one-ton exemption analysis.
  • • Not tracking Maryland separately from Mid-Atlantic sales.
  • • Treating gift sets and bundles as single undefined packaging items.

Penalties for Non-Compliance

Enforcement will follow Maryland program rules and statutory authority.

Frequently Asked Questions

What is Maryland's small producer exemption?

Maryland includes an exemption for producers below 1 ton into Maryland or below $2M in global gross revenue.

When are Maryland producer plans due?

Producer plans are due July 1, 2028.

What should brands do in 2026?

Brands should check obligations, prepare SKU sales data, and collect packaging material and weight evidence.

Does Maryland cover paper products?

Yes. Maryland's law covers packaging and paper products.

Can PackBOM help determine exemption status?

PackBOM can organize weight and sales data that supports your analysis, but exemption decisions should be reviewed by a qualified professional.

How PackBOM helps with Maryland compliance

PackBOM connects SKU sales, packaging BOMs, supplier evidence, AI spec extraction, validation rules, and report exports so your Maryland data is ready for review.

Start your Maryland EPR Data Audit

Related Resources

EPR Obligation Checker

Check whether your brand may need to comply with packaging EPR.

EPR Deadline Tracker

See deadlines across all current EPR states.

Multi-State EPR Checklist

Prepare data across California, Oregon, Colorado, and other states.