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)

Data/compliance support only — not legal advice. Confirm current authority before relying.