# Maine EPR pays towns the median cost of similar towns, and every producer date still waits on one contract

> Maine EPR, the Stewardship Program for Packaging in 38 M.R.S. section 2146 and DEP rule Chapter 428, makes producers pay a stewardship organisation that reimburses participating towns at the median per-ton cost of similar municipalities; producers pay within 180 days of that organisation's contract, which as of 1 November 2026 is not yet signed.

Publisher: Strategic Packaging Insights  
Published: 2026-11-01  
Last updated: 2026-11-01  
Page: https://www.strategicpackaginginsights.com/insights/maine-epr-packaging-stewardship-program-municipal-reimbursement/

**Maine EPR, the Stewardship Program for Packaging in 38 M.R.S. section 2146 and DEP rule Chapter 428, makes producers pay a stewardship organisation that reimburses participating towns at the median per-ton cost of similar municipalities; producers pay within 180 days of that organisation's contract, which as of 1 November 2026 is not yet signed.**

The Maine packaging EPR law dates from July 2021, and its rule was adopted in December 2024 and amended in March 2026. This guide sets out how the money moves, who pays, who is exempt, how the town formula works and what starts on contract day, using SPI Regulation Tracker record [PR-US-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-001/) and the primary texts.

## Executive summary

Maine was the earliest US state to enact a packaging extended producer responsibility (EPR) law, in July 2021, according to the Natural Resources Council of Maine (NRCM), a group that backed it. Public Law 2021, chapter 455 created 38 M.R.S. section 2146, and the Legislature amended it in 2023 and in June 2025. The Board of Environmental Protection adopted the rule, Chapter 428, in December 2024 and amended it to add Appendix A, the packaging material types list, effective 3 March 2026.

The design is unlike the other six state laws SPI tracks. In Oregon, Colorado, California, Minnesota, Maryland and Washington a producer responsibility organisation formed by producers runs the system. In Maine, the Department of Environmental Protection (DEP) tenders a single 10-year contract for a stewardship organisation, and every producer deadline runs from that contract's effective date (Exhibit 1).

The money follows a formula rather than a negotiation. Producers pay by tons and material type, with fees that differ for readily recyclable packaging and incentive fees for recycled content, toxicity, litter and labelling. Towns that opt in are paid the median per-ton cost of a group of similar municipalities. The December 2024 rule text grouped Maine's 16 counties into two sets, each split by population, giving four groups (Exhibit 10).

Small producers face two tests and one open question. Producers under one ton of Maine packaging are exempt, and those under 15 tons can pay a flat USD 500 per ton. On revenue, DEP's programme page and the statute describe the USD 2 million and USD 5 million lines over different contract years, so a USD 3 million company can read itself in scope or exempt in the same year (Exhibit 4). SPI presents both readings and does not resolve them.

The timing is the main business risk. DEP's first tender, RFP-202605094, closed on 18 August 2026 with no proposals, and on 28 October 2026 DEP said its revised RFP had gone to the Office of State Procurement and that towns would not be reimbursed for 2025 and 2026, as [SPI News reported](https://www.strategicpackaginginsights.com/news/maine-packaging-epr-no-reimbursements-2025-2026-rfp/). When a contract is signed, a 90-day registration window, the 180-day payment limit and a one-year sales bar start close together (Exhibit 13). Producers should have Maine tonnage by material type ready before then.

## Key findings

1. 38 M.R.S. section 2146 has 15 subsections; the SO must reimburse towns at the median per-ton cost of managing readily recyclable packaging and, separately, packaging that is not readily recyclable (section 2146(10)).
2. DEP said on 28 October 2026 that 111 municipalities had told it they intend to participate, and that no reimbursement will be paid for material recycled in 2025 and 2026.
3. The low-volume tier is capped at USD 500 per ton and USD 7,500 a year (section 2146(13)(A)); by SPI's calculation the annual cap is reached only at exactly 15 tons, the tier's upper edge, so for eligible producers the per-ton cap is the one that binds.
4. **SPI analysis:**  read as US short tons, USD 500 per ton is 25.0 cents per pound, the same figure as Oregon's 2026 rate for clear PET bottles and above Colorado's 14.0 cents for clear HDPE bottles.
5. The December 2024 Chapter 428 text set fees for packaging that is not readily recyclable at two times the average per-ton cost of the most expensive readily recyclable type, rising to up to five times in later years if goals are missed.
6. DEP's third draft material types list held 67 types, 22 of them readily recyclable, by SPI's count; SPI has not yet confirmed the counts in the adopted Appendix A.
7. **SPI calculation:**  at 12 cost studies a year, studying each of the 111 towns once takes about 9.3 years, in line with DEP's note that a recycling contractor can expect a study about once every 10 years.

## Maine EPR at a glance: what the packaging law does

The Maine packaging EPR law sits in one section of Title 38, with 15 numbered subsections. It defines terms, exempts small producers, sets up the SO contract, bars sales of noncompliant packaging, fixes producer payments and reporting, allows producer-run collection programmes, sets town duties and reimbursement, and lists what the fund may pay for (Exhibit 2). The current text carries the history note PL 2021, c. 455; PL 2023, c. 589; and PL 2025, c. 383, which amended sections 1 to 13 of the 2021 law.

DEP describes the purpose in one line on its programme page.

> "The program shifts the cost of managing packaging waste from taxpayers to the producers of packaging materials."

***Maine Department of Environmental Protection** , [Stewardship Program for Packaging](https://www.maine.gov/dep/waste/recycle/epr.html), programme page, consulted 1 November 2026*

The same page makes a second point that matters for packaging designers: the law prices packaging but does not ban formats.

> "The program does not ban packaging materials or establish packaging design standards."

***Maine Department of Environmental Protection** , [Stewardship Program for Packaging](https://www.maine.gov/dep/waste/recycle/epr.html), programme page, consulted 1 November 2026*

That separates Maine from laws such as California's SB 54, which sets source reduction and recyclability requirements. In Maine the lever is the fee: section 2146(13)(A) requires the payment schedule for producers above the low-volume tier to be adjusted to reward recycled content, recyclability, lower toxicity, less packaging, less litter, reuse and accurate labelling.

The fund has four uses under section 2146(12): municipal reimbursement, the SO's operating costs subject to a third-party financial audit, fees owed to DEP, and education and infrastructure investments approved under subsection 11. The statute sets no percentage split among them. The only dollar caps SPI found are DEP's annual fee, up to USD 300,000 under section 2146(13)(B), and an alternative collection programme oversight fee of up to USD 10,000 per participating producer under section 2146(13)(C).

## Who is the producer under the Maine packaging EPR law

Section 2146(1)(O) assigns the obligation by a fixed order, and the first party that fits is the producer (Exhibit 3). The order mirrors Oregon's and Colorado's in broad shape, which helps multi-state brands, but it ends with a Maine-specific last resort: the person that first distributes the product for sale in or into the state.

In practice: Ahold Delhaize USA and Hannaford.

The SPI [Buyers Database](https://www.strategicpackaginginsights.com/data/packaging-buyers-database/) profile for Ahold Delhaize records 2025 US net sales of EUR 53,063 million, all from East Coast banners, and notes that Hannaford trades in Maine under [PR-US-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-001/). For a grocer, the third place in the order matters most: own-label goods made by a contract packer under the retailer's brand fall to the brand owner unless the manufacturer sells under its own brand. SPI has not yet confirmed how Ahold Delhaize maps its own-label lines to the Maine order, because no Maine registration exists.

Section 2146(7) then sets what each producer reports to the SO every year: the total amount, by weight or volume, of each packaging material type sold, offered for sale or distributed in or into Maine in the prior calendar year. Since the June 2025 amendments, producers are not required to report annually by Universal Product Code (UPC), although DEP's September 2025 staff memo says a producer may still be asked for UPCs if audited.

## Maine EPR exemptions, and the revenue threshold that two official texts describe differently

Section 2146(2) exempts a producer in a given year on four grounds. It is outside the law if it distributed less than one ton of packaging material into Maine in the prior year, or earned more than 50% of gross revenue from insurance salvages, closeouts, bankruptcies and liquidations. The first 15 tons of packaging used for perishable food sold in or into Maine in the prior calendar year are also exempt. The fourth ground is revenue, and there the official texts diverge.

Some packaging is outside the definition altogether. Section 2146(1)(I) excludes packaging for a durable product expected to stay usable for at least 5 years, Bottle Bill beverage containers, architectural paint containers while an approved paint stewardship programme runs, and anything DEP excludes by rule. Subsection 13(D) asks DEP to review certain federally regulated products, such as drugs, medical devices and tamper-evident over-the-counter drug packaging, for possible exclusion by rule.

On revenue, DEP's programme page says producers with less than USD 2,000,000 in gross annual revenue are exempt for the first three years after the SO contract takes effect, and that from programme year four the threshold is less than USD 5,000,000. Section 2146(2)(A), as amended in 2025, reads differently. It exempts a producer under USD 2,000,000 in the prior calendar year, except that for the period beginning one calendar year after the contract's effective date and ending 3 years after it, a producer under USD 5,000,000 is exempt. DEP's own September 2025 staff memo to the Board describes the statute's version, a temporary USD 5 million line.

SPI analysis

For producers between USD 2 million and USD 5 million in revenue, the two readings point in opposite directions in every year after the first. A company that plans on DEP's page would budget Maine costs for three years and then drop them; one that plans on the statute would budget the first year, pause for two and then pay from year four. SPI has not yet confirmed which reading DEP will apply, and DEP's producer guidance, which its 28 October bulletin says is under development, is the place to watch. Until then, a firm in that band should keep both cases in its plan.

The comparison with other states shows why the line matters. SPI's tracker records give Minnesota's de minimis line as under USD 2,000,000 of global gross revenue or under one ton ([PR-US-006](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-006/)), and Oregon's as under USD 5 million of worldwide gross revenue or under one metric ton ([PR-US-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-002/)). Maine therefore sits at Minnesota's figure in some years and Oregon's in others, depending on the text. [Ledger 05](https://www.strategicpackaginginsights.com/insights/us-state-packaging-epr/) sets out the thresholds for all seven states.

## The low-volume tier: a flat USD 500 per ton below 15 tons

Above the exemptions, small producers can choose a simpler route. Section 2146(13)(A) requires the payment schedule to offer low-volume producers a flat fee option of no more than USD 500 per ton of packaging material and no more than USD 7,500 in total annual fees. The December 2024 rule text defines a low-volume producer as one that produced less than 15 tons of packaging in total in the prior calendar year, lets it report total tons by any estimation method by 31 May, and lets a producer that also reports by type pay the lesser of USD 500 per ton or the type-based amount.

**SPI calculation:**  because the tier stops below 15 tons, and 15 tons at USD 500 is exactly USD 7,500, the annual cap cannot bind for an eligible producer; the most a low-volume producer can pay is just under USD 7,500. At 5 tons the flat fee is USD 2,500, at 10 tons USD 5,000 and at 14 tons USD 7,000.

The rate is also worth reading in the units Oregon and Colorado use. Circular Action Alliance (CAA), the producer responsibility organisation in both, prints its 2026 schedules in US cents per pound, and SPI's [line-by-line Ledger on those schedules](https://www.strategicpackaginginsights.com/insights/oregon-colorado-epr-fee-schedules-line-by-line/) converts them to tonnes.

SPI analysis

For a small brand selling mostly paper and board, Maine's flat fee would sit well above what the same material pays per pound in Oregon, because the flat fee ignores material. For a brand selling hard-to-recycle plastics, the flat fee may be the cheaper route. The rule's option to pay the lesser of the flat fee or the type-based amount, for producers that report by type, is the way to test that once the SO publishes a schedule.

## How producer payments are built: material type, recyclability and incentive fees

For producers above the low-volume tier, section 2146(6) bases payments on the net amount, by weight or volume, of packaging not managed through an approved alternative collection programme, with separate calculations for readily recyclable and other material. Section 2146(1)(Q) defines readily recyclable as meeting the criteria DEP sets by rule, and those designations sit in Chapter 428 Appendix A.

DEP's programme page lists the base materials in its readily recyclable table as glass, metal, paper, PET (#1), HDPE (#2) and PP (#5), and says fees include an annual registration fee, material-specific fees and incentive fees. The December 2024 rule text set three tests for a readily recyclable designation: at least two facilities in North America recycle the material into non-fuel products, with capacity at least equal to supply; the material is common enough to sort; and at least 60% of the type's weight, on average, is made of materials routinely targeted for recycling.

DEP's September 2025 staff memo explains how the list was built. Outreach from March 2025 drew 77 comments from about 300 entities, and DEP aligned most types with Colorado and Oregon reporting categories, added a readily recyclable scoring sheet and revised the paper-based descriptions. The draft list illustrates the line drawn: clear PET bottles, natural HDPE bottles and uncoated corrugated board were marked readily recyclable, while pigmented PET bottles, carbon black HDPE bottles and expanded polystyrene cushioning were not.

The fee arithmetic in the December 2024 rule text is where recyclability bites (Exhibit 8). Readily recyclable types pay the average per-ton cost of recycling, reuse and composting that type in the prior year. Types that are not readily recyclable pay, per ton, two times the average per-ton cost of the most expensive readily recyclable type, and the multiplier rises to three, four or five times in later years depending on whether goals are met.

## Scenarios: what the multipliers mean for one ton of packaging

No SO means no cost data and no published fee per ton. The rule's structure can still be expressed as an index, setting the average per-ton cost of the most expensive readily recyclable type at 1.00. That keeps the calculation in the rule's own units and avoids inventing a Maine price.

**SPI calculation:**  in the base case the incentive fees add 0.40 to a type fee of 2.00 (10% plus 10% of 2.00), for 2.40. In the high case they add 2.00 to a type fee of 5.00 (10% plus 10% plus 20% of 5.00), for 7.00. The spread between low and high is seven to one, all in one currency and before any per-ton cost is known.

SPI analysis

The multiplier is the number to manage. A switch from a not readily recyclable format to a readily recyclable one removes the 2.00 to 5.00 starting point, while the incentive fees are percentages of whatever type fee applies. Design teams that already moved packs onto Oregon's or Colorado's recyclable lists for 2026 should check those formats against Maine's Appendix A, since DEP aligned most of its types with those two states.

## The reimbursement formula: a framework of four municipal groups

Section 2146(10) is the heart of the Maine packaging EPR law for towns. Each year the SO pays participating municipalities the median per-ton cost of managing readily recyclable packaging, and separately the median per-ton cost of managing packaging that is not readily recyclable, calculated from municipal cost reports, recycling facility data and audits. DEP's page puts it simply: a median cost is set for each group of similar municipalities, so towns below the median may receive more than their costs and towns above it less.

The December 2024 rule text sets out who is "similar" (Exhibit 10). Section 15 sorts participating towns by county and population. Eight southern and central counties split at an average population of 6,500, and eight northern, western and eastern counties split at 1,200. That gives a framework of four groups, which SPI uses to explain how the payments will behave.

The rule's handling of tons follows the same logic. Material from retailers is presumed not to be packaging and is deducted, material from other sources is presumed to be packaging, and where towns manage material jointly the tons are split per capita unless they agree otherwise. The SO multiplies each town's managed tons by the weight of each packaging type in a ton of the commodity, using audits sampled to 90% confidence, plus or minus 5%.

Reimbursement covers more than the readily recyclable stream. The rule text pays reusable and compostable types at the median reuse or composting cost, and pays recycled tons of non-readily recyclable types at the median recycling cost of readily recyclable material. DEP's page says towns may be reimbursed for all packaging material they send for recycling, whether or not it is designated readily recyclable.

SPI analysis

The median formula transfers risk to towns with high costs and rewards towns with low ones. Group D towns, the smallest in the most rural counties, will be compared only with each other, which protects them from being measured against Portland-area costs. For producers, the formula means total payments depend on how many towns opt in and how much they recycle, not on any town's actual bill.

## Cost studies: how the medians get built

The medians come from cost studies, and the study pipeline is slow by design. The December 2024 rule text states that the SO must conduct complete cost studies for 12 participating municipalities each year, prioritising three per group that lacks them, then towns never studied, then the oldest studies. A median for a pathway is set only when at least three current complete studies exist; if a group has fewer, all participating towns' studies are used, and with fewer than three in total no median is set.

DEP's 28 October bulletin confirms the pace from the town side: the SO will randomly select municipalities each year for cost studies, which set the median per-ton costs, and towns should prepare for possibly being among the first twelve. Studies cover labour, equipment, facilities, energy and contractor overhead or profit, with commodity revenue netted off, according to DEP's page.

> "Currently, 111 municipalities have notified the Department they intend to participate in the Packaging Program."

***Maine Department of Environmental Protection** , [Latest Updates on the Packaging Program Implementation Timeline](https://content.govdelivery.com/accounts/MEDEP/bulletins/430cecb), bulletin, 28 October 2026*

In practice: ecomaine.

The waste and recycling operator's guide for its communities, [EPR for Packaging in Maine](https://www.ecomaine.org/wp-content/uploads/2026/01/EPR-for-Packaging-in-Maine-1.pdf), told towns to record eligible expenses from January 2026, expected DEP to select an SO in spring 2026 and set the first reimbursements for fall 2027. It describes the median cost per ton as set by grouping similar towns by location and population, and lists the same cost categories as DEP. DEP's 28 October update has overtaken those dates, since no reimbursement will be paid for 2025 and 2026 material.

## The annual cycle once the programme runs

DEP's page sets a fixed calendar for each programme year (Exhibit 12). None of it applies until the SO contract takes effect and start-up registration has run, and DEP expects the first annual registration and reporting about one year after start-up registration, its 28 October bulletin says.

Start-up works differently. The 15 June 2026 bulletin said producers will have 90 days to register once the SO opens a start-up registration mechanism, and must estimate the tons they produced in a period the contract will set. The December 2024 rule text lets a producer that cannot estimate Maine tons report national tons, which the SO multiplies by Maine's share of the US population, and it caps start-up fees at each producer's share of one year of SO operating costs and the DEP fee.

Producers can also run their own scheme. Under section 2146(8), a producer or group may propose an alternative collection programme, which DEP must approve or deny within 120 days after public comment, for a term of 5 years. It offsets payment only for the same material type. DEP's page says applications open on the day DEP and the SO sign the contract, and that tons managed in one year offset fees invoiced the next.

## The contract clock: what starts on day zero

Every producer date in the Maine packaging EPR law counts from the effective date of the SO contract. DEP's RFP-202605094, published on 15 June 2026, closed at 4 p.m. on 18 August 2026 with no proposal submissions, DEP's 20 August bulletin said. On 28 October DEP said it had met interested organisations, revised the RFP and sent it to the Office of State Procurement for review and posting. Section 2146(3) allows DEP to reopen bidding where no compliant proposal is received.

In practice: Circular Action Alliance.

CAA runs the producer programmes in Oregon, Colorado, California, Minnesota and Maryland, as [Ledger 57](https://www.strategicpackaginginsights.com/insights/us-brand-owners-state-epr-kraft-heinz-general-mills-colgate-kimberly-clark-walmart/) sets out for five large brand owners. Its Maine page says it decided not to bid on the RFP for environmental packaging stewardship services, that the RFP as scoped did not align with its operational practices, systems and data stewardship standards, and that it remains committed to dialogue. SPI has not yet confirmed whether CAA will bid on the revised RFP.

SPI analysis

The clock compresses the work. On any contract date, registration, the first payment and the sales bar fall within one calendar year of each other, and the first two within six months. A producer that waits for the new timeline before it maps Maine tonnage by Appendix A type will be doing that mapping inside the 90-day window.

Enforcement follows the general Title 38 rules. Section 2146 sets no penalty of its own, and DEP administers and enforces it under subsection 13. Under 38 M.R.S. section 349, civil violations carry USD 100 to USD 10,000 a day, and Class E criminal violations USD 2,500 to USD 25,000 a day, with a USD 5,000 daily minimum for knowing violations. In practice the subsection 4 sales bar, with public lists of noncompliant producers, is the sharper tool; DEP may still let a producer sell other products whose packaging complies.

## Industry reaction

DEP's framing, quoted above, explains the town focus of the law: the money flows to municipal budgets, not to a producer-run collection system. The operator market has answered the tender differently.

> "Our decision was based on the scope of this specific RFP, not on Maine’s EPR goals or CAA’s interest in participating in Maine’s program."

***Circular Action Alliance** , [Maine page](https://circularactionalliance.org/maine), undated statement, consulted 1 November 2026*

The only organisation that runs packaging EPR in other US states has said it is not leaving Maine, but it has not said what change to the RFP would bring it back.

NRCM, which supported the law, estimates in its [fact sheet](https://www.nrcm.org/wp-content/uploads/2026/02/EPR-fact-sheet-2025.pdf) that Maine taxpayers pay about USD 16 million to USD 17 million a year in disposal costs, without giving a year or method, and says the producer money is distributed back to communities to help pay for recycling. ecomaine's guide tells towns that methods of recycling do not change under EPR. SPI has not yet confirmed a published response to the 28 October update from the Maine Municipal Association.

## What leaders should do now

1. **Regulatory affairs, by 31 March 2027:**  run the section 2146(1)(O) order for every SKU sold into Maine, record the party and clause relied on, and note any written assignment of responsibility.
2. **Packaging data teams, before the revised RFP is awarded:**  build Maine tons by Appendix A material type, and keep a national figure ready for population scaling in case start-up data is thin.
3. **Finance, in the 2027 and 2028 budgets:**  plan Maine costs on a trigger, the SO contract date plus 180 days, rather than a calendar date, and remove any accrual for 2025 and 2026 payments.
4. **Small producers between USD 2 million and USD 5 million in revenue, now:**  model both readings in Exhibit 4, and ask DEP in writing which applies in each contract year once its producer guidance appears.
5. **Packaging design, through 2027:**  check each Maine format against Appendix A, and prioritise moves off not readily recyclable types, where the rule text starts fees at twice the costliest recyclable type.
6. **Retail and sales teams, before the sales bar:**  plan supplier attestations of Maine compliance for the date one calendar year after the contract.
7. **Public affairs, at each DEP newsletter:**  follow the revised RFP and producer guidance, and use DEP's comment routes on the material types list where a format's designation affects cost.

## Questions for your board

- Which of our legal entities is the producer for each brand sold in Maine, and who has checked it against section 2146(1)(O)?
- If our revenue is between USD 2 million and USD 5 million, which reading of the exemption are we planning on, and what changes if the other applies?
- How many of our Maine tons sit in types DEP's list marks as not readily recyclable, and what would the Exhibit 9 multipliers mean for them?
- Could we use the low-volume flat fee, and would it cost more or less than the type-based amount for our material mix?
- How fast can we register and report once the SO opens registration with 90 days' notice?
- Would an alternative collection programme for any one material offset enough fees to justify a five-year commitment?

## What to watch

- **November 2026:**  DEP's first monthly newsletter under its new schedule, which may give the posting date of the revised RFP.
- **No date confirmed by SPI:**  the Office of State Procurement posts the revised RFP and its response deadline.
- **No date confirmed by SPI:**  DEP's producer guidance on producer identification, material types, registration, reporting, estimation and alternative collection programmes.
- **15 Feb 2027:**  DEP's annual report to the Legislature's environment and natural resources committee under section 2146(13)(E).
- **30 Apr 2027:**  towns file the Municipal Recycling Progress Report with a practice packaging section.
- **15 Feb 2028:**  DEP's report must include its five-yearly review of the programme rules.

## Methodology

- **Data used:**  SPI Regulation Tracker record [PR-US-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-001/) (data as of 14 October 2026), SPI fee-market data for Oregon and Colorado, and the SPI Buyers Database profile for Ahold Delhaize; the current text of 38 M.R.S. section 2146 and section 349; DEP's programme page and its bulletins of 15 June, 20 August and 28 October 2026; the Chapter 428 clean text placed before the Board on 5 December 2024; DEP's staff memo of 18 September 2025; DEP's third draft material types list. All primary texts consulted 1 November 2026.
- **Rule text:**  SPI read the Chapter 428 text placed before the Board in December 2024, not the consolidated text after the March 2026 amendment. The staff memo describes the amendments as adding Appendix A and aligning definitions and town duties with PL 2025, c. 383, without changes to the fee formula or groupings, but SPI has not yet confirmed each figure against the amended text.
- **Revenue exemption:**  DEP's programme page and section 2146(2)(A) describe the USD 2 million and USD 5 million lines over different contract years. SPI presents both and does not resolve them.
- **Counting rules:**  subsections, municipal groups and material types are counted by SPI from the texts. The material type counts come from DEP's third draft list.
- **Calculations:**  USD only, or index units from the rule's own multipliers, labelled SPI calculation. The cents per pound conversion assumes a US short ton of 2,000 pounds. The 1 July 2027 contract date in Exhibit 13 is illustrative, not a forecast.
- **Limitations:**  no SO contract, fee schedule, cost study or producer guidance existed on 1 November 2026. This is business analysis, not legal advice; check with counsel.

## Sources

1. Maine Legislature, Title 38, section 2146, Stewardship program for packaging, [https://legislature.maine.gov/statutes/38/title38sec2146.html](https://legislature.maine.gov/statutes/38/title38sec2146.html), consulted 2026-11-01.
2. Maine Legislature, Title 38, section 349, Penalties, [https://legislature.maine.gov/statutes/38/title38sec349.html](https://legislature.maine.gov/statutes/38/title38sec349.html), consulted 2026-11-01.
3. Maine Department of Environmental Protection, Stewardship Program for Packaging, [https://www.maine.gov/dep/waste/recycle/epr.html](https://www.maine.gov/dep/waste/recycle/epr.html), consulted 2026-11-01.
4. Maine Department of Environmental Protection, Latest Updates on the Packaging Program Implementation Timeline, bulletin, 28 October 2026, [https://content.govdelivery.com/accounts/MEDEP/bulletins/430cecb](https://content.govdelivery.com/accounts/MEDEP/bulletins/430cecb), consulted 2026-11-01.
5. Maine Department of Environmental Protection, Stewardship Organization RFP-202605094 Announcement: No Proposals Submitted as of Deadline, bulletin, 20 August 2026, [https://content.govdelivery.com/accounts/MEDEP/bulletins/425dec8](https://content.govdelivery.com/accounts/MEDEP/bulletins/425dec8), consulted 2026-11-01.
6. Maine Department of Environmental Protection, Shape Maine's Packaging Future: DEP Announces Stewardship Program RFP and Key Updates, bulletin, 15 June 2026, [https://content.govdelivery.com/accounts/MEDEP/bulletins/41c13c3](https://content.govdelivery.com/accounts/MEDEP/bulletins/41c13c3), consulted 2026-11-01.
7. Maine Department of Environmental Protection, Maine DEP to Revise Request for Proposals for Stewardship Organization, bulletin, 11 September 2026, [https://content.govdelivery.com/accounts/MEDEP/bulletins/429cf26](https://content.govdelivery.com/accounts/MEDEP/bulletins/429cf26), consulted 2026-10-14.
8. Maine Board of Environmental Protection, Chapter 428 proposed rule, clean text, meeting of 5 December 2024, [https://www.maine.gov/dep/bep/2024/12-05-24/Chapter%20428%20Proposed%20Rule%20clean.pdf](https://www.maine.gov/dep/bep/2024/12-05-24/Chapter%20428%20Proposed%20Rule%20clean.pdf), consulted 2026-11-01.
9. Maine Department of Environmental Protection, staff memo to the Board on Chapter 428 amendments, 18 September 2025, [https://www.maine.gov/dep/bep/2025/10-16-25/Chapter%20428%20Staff%20Memo.pdf](https://www.maine.gov/dep/bep/2025/10-16-25/Chapter%20428%20Staff%20Memo.pdf), consulted 2026-11-01.
10. Maine Department of Environmental Protection, Initial Packaging Material Types List, third draft, [https://www.maine.gov/dep/ftp/temp/epr/background/AppendixA/ThirdDraft/Initial%20Packaging%20Material%20Types%20List.pdf](https://www.maine.gov/dep/ftp/temp/epr/background/AppendixA/ThirdDraft/Initial%20Packaging%20Material%20Types%20List.pdf), consulted 2026-11-01.
11. J. J. Keller Compliance Network, Maine lists materials covered for packaging stewardship program, 24 April 2026, [https://jjkellercompliancenetwork.com/news/maine-lists-materials-covered-for-packaging-stewardship-program](https://jjkellercompliancenetwork.com/news/maine-lists-materials-covered-for-packaging-stewardship-program), consulted 2026-11-01.
12. Circular Action Alliance, Maine, [https://circularactionalliance.org/maine](https://circularactionalliance.org/maine), consulted 2026-11-01.
13. Natural Resources Council of Maine, EPR fact sheet, [https://www.nrcm.org/wp-content/uploads/2026/02/EPR-fact-sheet-2025.pdf](https://www.nrcm.org/wp-content/uploads/2026/02/EPR-fact-sheet-2025.pdf), consulted 2026-11-01.
14. ecomaine, EPR for Packaging in Maine, [https://www.ecomaine.org/wp-content/uploads/2026/01/EPR-for-Packaging-in-Maine-1.pdf](https://www.ecomaine.org/wp-content/uploads/2026/01/EPR-for-Packaging-in-Maine-1.pdf), consulted 2026-11-01.
15. Circular Action Alliance, 2026 Oregon Producer Fee Schedule, [https://static1.squarespace.com/static/64260ed078c36925b1cf3385/t/693b2c9103be112d168e1b19/1765485713621/OR+2026+Fee+Schedule+Public.pdf](https://static1.squarespace.com/static/64260ed078c36925b1cf3385/t/693b2c9103be112d168e1b19/1765485713621/OR+2026+Fee+Schedule+Public.pdf), consulted 2026-10-14.
16. Circular Action Alliance, 2026 Colorado Producer Dues Schedule, [https://static1.squarespace.com/static/64260ed078c36925b1cf3385/t/693b45923163e42ba98d634f/1765492118120/CO+2026+Dues+Schedule+Public.pdf](https://static1.squarespace.com/static/64260ed078c36925b1cf3385/t/693b45923163e42ba98d634f/1765492118120/CO+2026+Dues+Schedule+Public.pdf), consulted 2026-10-14.
17. Oregon Department of Environmental Quality, Producer Obligations Summary, Recycling Modernization Act, [https://www.oregon.gov/deq/recycling/Documents/RMAProducerObligationsSummary.pdf](https://www.oregon.gov/deq/recycling/Documents/RMAProducerObligationsSummary.pdf), consulted 2026-10-14.
18. SPI Regulation Tracker, PR-US-001, Maine Stewardship Program for Packaging, and records PR-US-002 and PR-US-006, /data/packaging-regulation-tracker/united-states/pr-us-001/, consulted 2026-11-01.
19. SPI News, Maine DEP says towns get no packaging EPR money for 2025 and 2026 after its first operator tender drew no bids, 30 October 2026, /news/maine-packaging-epr-no-reimbursements-2025-2026-rfp/, consulted 2026-11-01.
20. SPI Buyers Database, Ahold Delhaize profile, /data/packaging-buyers-database/, consulted 2026-11-01.