Which EPR dates are confirmed and which are expected
EPR outreach lives or dies on date discipline. Five dates circulate; each carries a different status. Conflating them is how “expected” becomes “guaranteed” in a sales email.
The five dates (at last review 2026-09-21)
| Date | Statement | Confidence |
|---|---|---|
| Oct 4, 2026 | SB 343 labeling restrictions keyed to products/packaging manufactured after this date — enforcement preliminarily enjoined | High on date and injunction; monitor docket |
| Oct 13, 2026 | CAA submits final draft California program plan to CalRecycle; 2027 schedule expected in the process | Scheduled, not completed or approved |
| Jan 1, 2027 | PRC §42051(b) sales restriction: covered producer generally must be approved in an approved PRO plan or qualify for an individual pathway | Statutory; client status is fact-specific |
| Jan 2027 | Oregon and Colorado expected to invoice 2027 fees | Operational expectation from 2026 pattern, not a uniform statutory date |
| May 31, 2027 | Anticipated annual CAA reporting window for 2026 data in active/reporting programs | Reconfirm per state and report type; not fixed until CAA/state calendars publish |
Also note: May 31 was the common CAA reporting date for six programs in 2026 — an operational pattern, not one uniform statutory deadline. Maine is off that clock while it has no contracted stewardship organization.
Rule used in this practice
Confirmed dates go in plans; expected dates go in plans labeled expected with the condition attached. No client statement or filing uses a date without rechecking the primary source first.
Sources (retrieved 2026-09-21)
- CAA Producer Resource Center — https://circularactionalliance.org/producer-resource-center
- CAA California — https://circularactionalliance.org/california
- CAA Oregon — https://circularactionalliance.org/oregon
- CAA Colorado — https://circularactionalliance.org/colorado
- CalRecycle SB 343 page — https://calrecycle.ca.gov/wcs/recyclinglabels/
Data/compliance support only — not legal advice. Confirm current authority before relying.