Germany vs Oregon EPR: Rules Compared
Last verified
Germany and Oregon both run packaging EPR, but the rules differ. Both require producers to register. Germany asks for its first annual report earlier, on May 15 against May 31 in Oregon. Every figure below links to its primary source.
Germany and Oregon side by side
2 of 9 rows have a verified figure on each side of Germany and Oregon; a cell reads “not yet published” when a side has none, and an exemption row reads “none recorded; see thresholds” when no exemption is on record.
| Measure | Germany | Oregon | Stricter |
|---|---|---|---|
| Registration duty | Required | Required | Same |
| Producer organisation | more than one producer responsibility organisation | one producer responsibility organisation | Not comparable |
| Lowest revenue exemption | none recorded; see thresholds | $5,000,000 | Not comparable |
| Lowest weight exemption | none recorded; see thresholds | 1 tonne | Not comparable |
| First annual report date | May 15 | May 31 | Germany |
| Published penalties | not yet published | 1 published | Not comparable |
| Report file | xml | csv | Not comparable |
| Paper fee, cheapest matched rate | not yet published | 2.0 cents per pound | Not comparable |
| Plastic fee, cheapest matched rate | not yet published | 12.0 cents per pound | Not comparable |
Both programmes require a producer to register, in Germany and in Oregon.
The earliest annual report date is May 15 in Germany and May 31 in Oregon, 16 days apart. Germany leaves less time to prepare, so its data has to be ready first.
Who runs the programme in Germany and Oregon
Who collects and who the producer files with, in Germany and then Oregon.
| Aspect | Germany | Oregon |
|---|---|---|
| Regime | Packaging producer responsibility: register in LUCID, participate packaging subject to system participation in a dual system, and report volumes | Oregon Recycling Modernization Act, ORS 459A.860 to 459A.975 (SB 582 of 2021) |
| Regulator | Zentrale Stelle Verpackungsregister (ZSVR), which runs the LUCID Packaging Register; competent state authorities enforce | Oregon Department of Environmental Quality (DEQ) |
| Producers obligated | Yes | Yes |
| Registration | Required, LUCID Packaging Register (ZSVR) | Required, Circular Action Alliance producer portal (PRO registration); DEQ holds no separate producer registry |
| Producer organisation | more than one producer responsibility organisation; membership optional | one producer responsibility organisation: Circular Action Alliance; membership required |
| Transfer of responsibility | Allowed | Allowed |
| Revenue counted as | not yet published | organisation gross revenue, USD, fiscal year |
| Who counts as the producer | other: manufacturer or brand owner, manufacturer, importer, first distributor, authorised representative; primary: manufacturer or brand owner, importer, first distributor, authorised representative; secondary: manufacturer or brand owner, importer, first distributor, authorised representative; service: manufacturer or brand owner, manufacturer, importer, first distributor, authorised representative; shipping: manufacturer or brand owner, packer and shipper, importer, first distributor, online marketplace seller, authorised representative; tertiary: manufacturer or brand owner, manufacturer, importer, first distributor, authorised representative | other: first distributor; primary: manufacturer or brand owner, brand licensee, importer; secondary: manufacturer or brand owner, brand licensee, importer; service: first distributor; shipping: packer and shipper; tertiary: first distributor |
The two programmes are organised differently. Germany uses more than one producer responsibility organisation; Oregon uses one producer responsibility organisation. For a seller in both, that usually means two different counterparties, two different sign-up routes and two different sets of terms to read before the first report is due.
What Germany and Oregon cover, side by side
Each row below is one published feature of the two programmes; a cell reads “not yet published” when Germany or Oregon has no verified entry for it in the dataset.
| Aspect | Germany | Oregon |
|---|---|---|
| Materials covered | paper and card, glass, plastic, steel, aluminium, fibre based composite, other | packaging, printing and writing paper, food serviceware |
| Product classes covered | primary packaging, secondary packaging, shipment packaging, tertiary packaging, reusable packaging | packaging, printing and writing paper, food serviceware |
| Sales channels addressed | retail, wholesale, online, online marketplace | physical retail, remote sale, other distribution |
| Producer duty: primary packaging | manufacturer_brand_owner; importer; first_distributor; authorised_representative | manufacturer_brand_owner; licensee; importer |
| Producer duty: secondary packaging | manufacturer_brand_owner; importer; first_distributor; authorised_representative | manufacturer_brand_owner; licensee; importer |
| Producer duty: tertiary packaging | manufacturer_brand_owner; manufacturer; importer; first_distributor; authorised_representative | first_distributor |
| Producer duty: shipping packaging | manufacturer_brand_owner; packer_shipper; importer; first_distributor; online_marketplace_seller; authorised_representative | packer_shipper |
| Producer duty: service packaging | manufacturer_brand_owner; manufacturer; importer; first_distributor; authorised_representative | first_distributor |
| Producer duty: other packaging | manufacturer_brand_owner; manufacturer; importer; first_distributor; authorised_representative | first_distributor |
| Excluded from scope | not yet published | beverage containers under bottle bill, bound books, napkins paper towels and cleaning paper, rigid pallets, industrial or manufacturing specialty packaging, drug packaging, items used or sold on a farm, architectural paint containers in paint stewardship, privately recycled material on claim |
| Reporting categories | not yet published | 60, covered material type by material class |
| Published targets | not yet published | statewide_plastic_recycling_rate 25 by 2028-12-31; statewide_plastic_recycling_rate 50 by 2040-12-31; statewide_plastic_recycling_rate 70 by 2050-12-31 |
| Exemption 1 | not yet published | A small producer is exempt from PRO membership. Seven ways to qualify: nonprofit, public body, revenue under $5 million, under 1 metric ton, small beverage manufacturer, restaurant or food cart that is not a food-serviceware producer, single retail establishment with no online sales and no franchise or chain. |
| Exemption 2 | not yet published | Product-specific exclusions from "covered product" listed in ORS 459A.863(6)(b)(A)-(R) and OAR 340-090-0840(2), such as Bottle Bill containers, bound books, drug packaging, farm items and architectural paint containers. |
| Exemption 3 | not yet published | Material recycled through a non-Opportunity-to-Recycle collection, not separated at a commingled facility, and disposed to a responsible end market can be exempted if the producer demonstrates it to DEQ. Producers still report gross supply. (application needed) |
Thresholds and exemptions in Germany and Oregon
Every verified threshold Germany and Oregon publish, as each states it.
| Place | Measure | Amount | Effect | Basis as published |
|---|---|---|---|---|
| Germany | packaging tonnage | 80 tonnes | declaration-of-completeness trigger | glass placed on the German market in the previous calendar year (reached or exceeded) |
| Germany | packaging tonnage | 50 tonnes | declaration-of-completeness trigger | paper, paperboard and cardboard in total, previous calendar year (reached or exceeded) |
| Germany | packaging tonnage | 30 tonnes | declaration-of-completeness trigger | ferrous metals, aluminium, plastics, beverage cartons and other composites in total, previous calendar year (reached or exceeded) |
| Germany | packaging tonnage | 10 tonnes | reduced duty | packaging subject to system participation made available for the first time in the previous calendar year |
| Oregon | revenue | $5,000,000 | exempt below | gross revenue, most recent fiscal year |
| Oregon | packaging tonnage | 1 metric ton | exempt below | covered products sold in or into Oregon, most recent calendar year |
| Oregon | packaging tonnage | 5 metric tons | exempt below | covered products, including secondary and tertiary packaging for beverage containers, most recent calendar year |
| Oregon | revenue | $10,000,000 | flat-fee band | gross revenue, most recent fiscal year, or under 5 metric tons sold in or into Oregon |
Oregon exemption: A small producer is exempt from PRO membership. Seven ways to qualify: nonprofit, public body, revenue under $5 million, under 1 metric ton, small beverage manufacturer, restaurant or food cart that is not a food-serviceware producer, single retail establishment with no online sales and no franchise or chain. It does not have to be applied for.
Oregon exemption: Product-specific exclusions from "covered product" listed in ORS 459A.863(6)(b)(A)-(R) and OAR 340-090-0840(2), such as Bottle Bill containers, bound books, drug packaging, farm items and architectural paint containers. It does not have to be applied for.
Oregon exemption: Material recycled through a non-Opportunity-to-Recycle collection, not separated at a commingled facility, and disposed to a responsible end market can be exempted if the producer demonstrates it to DEQ. Producers still report gross supply. It must be applied for.
Read the basis column first: the same amount can exempt a producer in one programme and only simplify its report in another.
Fees per kilogram for shared materials
Oregon publishes per-kilogram rates in the dataset; Germany does not. Reason: Dual-system participation fees are set by each operator's contract and no public tariff has been retrieved; the fee engine asks for the customer's contracted rates instead of estimating. The rows therefore show Oregon only. Until both sides publish per-kilogram rates for the same material class, a fee comparison between Germany and Oregon would mean inventing a figure, and this page does not do that.
Oregon: the 2027 fee schedule of Circular Action Alliance (Oregon PRO), effective January 1, 2027, is the source of the per-kilogram rates used on this page.
Oregon 2027: the category “Kraft Paper” is published at 2.0 cents per pound.
Oregon 2027: the category “HDPE (#2)/LDPE (#4) Flexible and Film Items” is published at 12.0 cents per pound.
Oregon 2027: the category “Glass Bottles and Jars & Other Containers” is published at 0.0 cents per pound.
Deadlines in Germany and Oregon
Each verified date, with the period it covers when one is given.
| Place | Kind | Date | Covers |
|---|---|---|---|
| Germany | report | June 1, 2027 | calendar year 2026 |
| Germany | report | December 31, 2026 | calendar year 2027 |
| Germany | report | May 15, 2027 | calendar year 2026 |
| Oregon | report | May 31, 2026 | calendar year 2025 |
| Oregon | other | July 1, 2025 | not yet published |
| Oregon | other | January 1, 2027 | not yet published |
| Oregon | report | December 31, 2026 | not yet published |
The earliest annual report date is May 15 in Germany and May 31 in Oregon, 16 days apart. Germany leaves less time to prepare, so its data has to be ready first.
Penalties in Germany and Oregon
What each side has published; a side without an amount says so.
Oregon penalty for failing to register or become a member of a producer responsibility organization: up to $25,000 per day.
Report formats in Germany and Oregon
How the report file for Germany compares with the one for Oregon.
| Aspect | Germany | Oregon |
|---|---|---|
| Layout | LUCID producer volume report (XML upload, section 10 VerpackG) XML interface 1.0, guide version 1.3 (12 August 2026), VerpackG material codes (reports 2019 to 2026) | Oregon producer supply report by material category 2026-09-29 (built from CAA Oregon 2026 fee schedule) |
| Recipient | Stiftung Zentrale Stelle Verpackungsregister (ZSVR), LUCID packaging register | Circular Action Alliance (Oregon PRO) |
| How it is submitted | LUCID XML upload. The customer signs in, uploads the file, checks the displayed data and confirms. | CAA producer portal. The customer signs in and submits. |
| File type | xml | csv |
| Encoding | utf-8-sig | utf-8 |
| Delimiter | not yet published | , |
| Decimal separator | , | . |
| Columns | 8 | 4 |
| Required columns | 8 of 8 | 4 of 4 |
| Weight unit | kg | lb |
| Period basis | calendar year | calendar year |
Germany report specification: XML producer volume report with elements VersionNoInterface, PackagingTypeCode, TypeOfReportCode, ReportingPeriodFrom, ReportingPeriodTo and one SystemOperator with its SystemOperatorID and a Material list (MaterialCode, Mass).
The two layouts differ in file shape as well as in columns, so a report built for Germany cannot be sent to Oregon unchanged. Each report is built from the same underlying measurements and exported separately.
Which to plan for first, Germany or Oregon
Plan around the earlier report date first. Germany asks for its first annual report on May 15, before Oregon, so its data has to be ready first.
Questions about comparing these two programmes
Is Germany or Oregon stricter on packaging EPR?
Both require producers to register. Germany asks for its first annual report earlier, on May 15 against May 31 in Oregon.
Do I register in both Germany and Oregon?
Germany requires producers to register. Oregon requires producers to register.
How do the fees per kilogram compare in Germany and Oregon?
The dataset does not hold per-kilogram rates for the same material class on both sides, so this page does not compare fees.
Which deadline comes first, Germany or Oregon?
The earliest annual report date is May 15 in Germany and May 31 in Oregon, 16 days apart. Germany leaves less time to prepare, so its data has to be ready first.
How these figures are made
Sources
- verpackungsregister.org: system participation retrieved
Original wording: you must finance the recycling of your packaging by participating that packaging in a system.
Original wording: You can conclude your system participation agreement with the system operator of your choice.
Original wording: you are required to conclude a system participation agreement with a system operator.
- verpackungsregister.org: declaration of completeness retrieved
Original wording: The Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) and the competent state authorities
Original wording: Glass: 80 tonnes
Original wording: Paper, paperboard, cardboard (PPC) in total: 50 tonnes
Original wording: Ferrous metals + aluminium + plastics + beverage cartons + other composites (lightweight packaging) in total: 30 tonnes
Original wording: by no later than 15 May of any given year for the previous year.
- verpackungsregister.org: find out about registrations retrieved
Original wording: If you are distributing packaged goods in Germany, you have to be registered with the LUCID Packaging Register.
Original wording: you must register with the LUCID Packaging Register. Registering is free of charge.
Original wording: There are two different packaging categories: packaging subject to system participation and packaging not subject to system participation.
- verpackungsregister.org: distinguishing between manufacturers producers retrieved
Original wording: A producer is every natural or legal person who, as a manufacturer, importer or distributor, makes a unit of packaging available for the first time
- verpackungsregister.org: data reporting retrieved
Original wording: A simplified reporting requirement applies to producers who made available less than 10 tonnes of packaging subject to system participation
Original wording: Year-end volume reports for the previous year (actual volumes) can only be filed up to 1 June.
Original wording: Initial planned volume reports for the following year can only be filed by 31 December of the current year.
- oregon.gov: producers of covered products retrieved
Original wording: producers of products covered under Oregon's Recycling Modernization Act (packaging, paper, and food serviceware)
Original wording: Circular Action Alliance, at present, is Oregon's only approved Producer Responsibility Organization
Original wording: In order to access CAA's data reporting portal, producers must first sign the Producer Participant Agreement with CAA
Original wording: was allowed to begin charging fees from member producers on July 1, 2025
Original wording: Large producer first impact disclosure date of Dec. 31, 2026
Original wording: is a Class 1 violation that can result in fines of up to $25,000 per day.
- oregon.public.law: ors 459A.869 retrieved
Original wording: each producer must register with and be a member of a producer responsibility organization that administers a producer responsibility program
Original wording: A producer is not required to be a member of a producer responsibility organization if, for all covered product the producer sells
- oregon.public.law: ors 459A.863 retrieved
Original wording: Has a gross revenue of less than $5 million for the organization's most recent fiscal year
Original wording: Sold in or into Oregon less than one metric ton of covered products for use in this state in the most recent calendar year
Original wording: that sold in or into Oregon less than five metric tons of covered products
Original wording: "Covered product" means: (A) Packaging; (B) Printing and writing paper; and (C) Food serviceware.
- oregon.public.law: ors 459A.866 retrieved
Original wording: the producer of the packaging is the person that manufactures the packaged item
- oregon.public.law: ors 459A.884 retrieved
Original wording: a producer responsibility organization shall establish uniform membership fees for members that had a gross revenue of less than $10 million
- oregon.public.law: ors 459A.872 retrieved
Original wording: A small producer is exempt from the requirement to be a member of a producer responsibility organization
- oregon.gov: rma exemptions retrieved
Original wording: Covered product exemptions, meanwhile, are product-specific exemptions that exclude a given type of packaging
Original wording: The latest window for producers to submit claims for this exemption was Jan. 6 – March 31, 2026
Original wording: The next claims window will open in Jan. 2027.
- circularactionalliance.org: producer reporting retrieved
Original wording: Oregon's 2026 Report is due May 31, 2026, based on the 2025 Data Year.
- circularactionalliance.org: OR 2026 Fee Schedule Public retrieved
Original wording: Materials labeled N/A in the following table are not accepted on either the USCL or PRO Recycling Acceptance List.
- oregon.public.law: ors 459A.926 retrieved
Original wording: At least 25 percent by calendar year 2028 and in each subsequent year
- circularactionalliance.org: OR 2027FeeSchedule 100126 retrieved
Original wording: 2027 Oregon Producer Fees Schedule Fees for Program Year 2027
Original wording: Kraft Paper USCL 0.07 0.00 -0.05 0.02
Original wording: HDPE (#2)/LDPE (#4) Flexible and Film Items PRO 0.29 0.00 -0.17 0.12
Original wording: Glass Bottles and Jars & Other Containers PRO 0.04 -0.01 -0.03 0.00
- verpackungsregister.org: Anleitung XML Datenmeldung EN retrieved
Original wording: Mass: packaging material mass in kg to the third decimal place without thousands separators (decimal place demarcated with comma).
The free plan is enough to start. We estimate and prepare; you sign and submit.