Summary
Details
- Oregon
Covered producers generally must:
Determine producer status.
Register with an approved PRO.
Report covered material data.
Pay required producer fees.
Maintain accurate supply information.
Follow applicable program-plan requirements.
The largest producers have additional life cycle evaluation obligations.
The Act includes exemptions for certain producers and products.
Important examples include:
Small producers meeting statutory criteria.
Certain materials managed through qualifying private recycling systems.
Specific product categories excluded by statute or rule.
Materials qualifying for other defined exemptions.
Exemptions should be assessed against the current statute and administrative rules rather than assumed based only on company size or packaging type.
Deep dive
- What’s Required
- 1. Determine whether the company is a producer
- 2. Identify covered products
- 3. Join an approved Producer Responsibility Organization
- 4. Report covered product data
- 5. Pay producer responsibility fees
- 6. Support recycling system modernization
- 7. Life cycle impact evaluations for the largest producers
- 8. Responsible end markets
- 9. Private recycling exemption
- Important Deadlines
- Current Status
- Penalties for Non-Compliance
- Examples of Known Violations / Failure Modes
- Resources
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What’s Required
1. Determine whether the company is a producer
Companies placing covered products into Oregon must determine which entity is legally responsible under the statutory producer hierarchy.
Depending on the product and business arrangement, the responsible entity may be:
Brand owner.
Manufacturer.
Importer.
Distributor.
Publisher or other designated party.
2. Identify covered products
The Act broadly covers:
Packaging.
Paper products.
Food serviceware.
Businesses need detailed information about materials, formats, weights, and quantities supplied into Oregon.
3. Join an approved Producer Responsibility Organization
From 2025 onward, covered producers generally must register with an approved PRO.
Circular Action Alliance (CAA) is currently the only approved PRO operating under Oregon’s program. Oregon DEQ approved its 2025-2027 program plan in February 2025.
4. Report covered product data
Producers must report information to their PRO on covered products supplied in or into Oregon.
Relevant data can include:
Material category.
Packaging type.
Weight.
Quantity.
Product format.
Applicable exemptions.
Producer fees are linked to reported material supply, making accurate packaging data central to compliance.
5. Pay producer responsibility fees
The approved PRO began charging producer fees from July 1, 2025.
Fees fund activities including:
Recycling collection.
Processing.
Transportation.
System improvements.
Education.
Recycling infrastructure.
Responsible end-market management.
Fee rates vary depending on covered material and change over time.
6. Support recycling system modernization
Producer funding supports improvements intended to create more consistent recycling services across Oregon.
The framework aims to:
Expand recycling access.
Modernize processing.
Reduce contamination.
Standardize accepted materials.
Improve end-market accountability.
Shift more recycling costs from local communities to producers.
7. Life cycle impact evaluations for the largest producers
The 25 largest producers by weight of covered products have additional obligations.
They must evaluate and disclose life cycle impacts for 1% of their covered products on a biennial basis. The first major disclosure deadline is December 31, 2026, for producers covered by the initial requirement.
8. Responsible end markets
Materials counted toward recycling performance need to be sent to qualifying responsible end markets.
The framework seeks greater transparency concerning:
Where materials go.
How they are processed.
Whether recycling actually occurs.
Environmental and worker protections.
Downstream material management.
9. Private recycling exemption
Certain materials recycled through private systems outside the commingled recycling system may qualify for an exemption from corresponding producer fees where statutory conditions are satisfied.
For the 2027 fee year, the exemption application window ran from January 6 through March 31, 2026.
Important Deadlines
August 6, 2021: SB 582 signed into law.
2024-2025: Producers prepared registration and covered material data.
February 21, 2025: DEQ approved CAA’s initial 2025-2027 program plan.
July 1, 2025: Operational producer responsibility program began, and producer fees could be charged.
May 31, 2026: CAA anticipated producer reporting deadline for 2025 supply data used for the 2027 fee cycle.
December 31, 2026: First life cycle impact evaluations due from applicable top-25 producers.
2026-2027: Oregon DEQ is conducting a third rulemaking process to clarify and update implementation requirements.
Current Status
Active and legally binding.
Oregon’s EPR system has been operational since July 2025.
In 2026, producers are already reporting covered materials and paying PRO fees, while the Oregon Department of Environmental Quality continues rulemaking on issues including exemptions, responsible end markets, recycling acceptance lists, and program implementation.
The current rulemaking is expected to reach the Environmental Quality Commission for potential final action in early 2027.
Penalties for Non-Compliance
Failure to register or become a member of a Producer Responsibility Organization can constitute a Class 1 violation.
Oregon DEQ states that such violations can result in penalties of up to US$25,000 per day.
Other consequences can include:
Enforcement orders.
Additional civil penalties.
Corrective reporting requirements.
Payment of outstanding fees.
Regulatory investigation.
Restrictions affecting compliant market participation.
Examples of Known Violations / Failure Modes
Failing to register with the approved PRO.
Supplying covered products without meeting producer obligations.
Underreporting packaging or paper quantities.
Incorrectly identifying the responsible producer.
Missing producer fee payments.
Incorrect material classification.
Claiming an exemption without satisfying the conditions.
Double counting privately recycled materials.
Reporting materials as recycled without a responsible end market.
Missing required life cycle impact disclosures.
Failing to update supply data annually.
Assuming food serviceware falls outside the program.
Treating participation in CAA as automatic compliance with every Oregon waste requirement.
Resources
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