Hurry Up and Wait

This is the third in a series of Verrill blog posts on Maine’s packaging extended producer responsibility (“EPR”) law[1]. In July we reported that the Maine Department of Environmental Protection (“DEP”) anticipated that packaging producers should be prepared to register under the EPR regulations in late 2026 or early 2027. However, on August 8, the DEP announced that it had received no responses to its Request for Proposals to serve as the state’s Stewardship Organization under the EPR program. Absent a Stewardship Organization that would be responsible for developing the producer registration process and to administer the EPR program, deadlines under the program will slip considerably. As of today, there is no timeline for producers to register or pay fees under the EPR program. According to the DEP announcement “the Department is assessing all options at this time; further information will be forthcoming in a future newsletter.”

As previously reported, Maine is one of only seven states with a packaging EPR law. Each of the six other states has selected a not-for-profit organization known as Circular Action Alliance as its Producer Responsibility Organization (‘PRO”), the equivalent to the “Stewardship Organization” for which Maine DEP was soliciting proposals. According to an article on the subject by Packaging Dive “Circular Action Alliance chose not to submit a proposal to the Maine DEP. The six other states with packaging EPR programs did not conduct the same type of RFP processes. Maine’s EPR law also differs structurally, due in part to a municipal reimbursement model.”

Stay tuned for future Verrill blog posts on the roll out (or lack thereof) of Maine’s packaging EPR program. Meanwhile, you can access the Maine DEP’s announcements regarding the program at this website: Extended Producer Responsibility for Packaging, Waste Management, Maine Department of Environmental Protection.

[1] Those posts were: an Update on Status of Maine Packaging EPR – Verrill July 27, 2026, and Unwrapping Maine’s Gift to the Environment: A New Packaging Stewardship Program Set to Launch in 2026 on December 26, 2024