Maryland Issues Final EPR Regulations
Maryland passed a Producer Packaging Responsibility Law in 2023 (2023 Regular Session – Fiscal and Policy Note for Senate Bill 222) and Maryland Department of the Environment (MDE) has been working on regulations since then. We anticipated the 2026 Legislature would pass a beverage container deposit law satisfying an express exemption in the EPR law for beverage containers; we worked with sponsors throughout 2025 and the 2026 Session to ensure the legislation accommodated issues unique to wine products. However, a deposit law did not pass in Maryland in 2026. Because of this, member wineries selling product into Maryland above annual sales thresholds in the law now must begin the process of registering with the MD Producer Responsibility Organization (PRO) which is Circular Action Alliance (CAA). We continue to expect a beverage container deposit law to pass in 2027, but until that time, wineries must register as if the EPR law applies to their beverage containers and packaging. MD DEP finally issued regulations on May 25, 2026, six days before the May 31 deadline CAA has given for producers to register with them.
See CAA’s Maryland webpage with details about the program and producer registration at Maryland — Circular Action Alliance. Producers must register and provide “simplified reporting” to CAA by May 31, 2026 to enable CAA to meet its July 1, 2026 deadline for providing MDE with a list of producers, brands and material type information. Producers will be required to report to CAA again by May 31 each year as part of the PRO’s submission requirements to MDE. An initial Producer Responsibility Plan prepared by CAA must be submitted to MDE for approval by July 1, 2028. Producers will start reimbursing a percentage of collection and processing costs by July 1, 2028; collection of fees will likely begin before then; fees and dates have not yet been determined.
Find a link to the final EPR regulations here: 26.04.14.02B(6)(b) | Library of Maryland Regulations. Also find a link to the regulations as initially proposed by MDE on 2/26/26, all revisions to those regulations made on 5/10/26, and all public comments to MDE on the regulations, as well as MDE responses: Producer Responsibility. Find the May 2026 CAA Newsletter here: CAA Producer Actions and Key Dates – May 2026. Please refer to the links within or the Wine Institute’s EPR webpage for more details.