# Germany vs Oregon EPR: Rules Compared

Last verified: November 5, 2026 · https://instica.com/epr/compare/germany-vs-oregon

<a id="answer"></a>

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.

<a id="glance"></a>

## 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.

<a id="glance-table"></a>**Germany and Oregon: the measures both programmes publish**

| 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 |

<a id="calc-registration"></a>Both programmes require a producer to register, in Germany and in Oregon.

<a id="calc-report-date"></a>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.

<a id="programme"></a>

## Who runs the programme in Germany and Oregon

Who collects and who the producer files with, in Germany and then Oregon.

<a id="programme-table"></a>**Germany and Oregon: how each programme is set up**

| 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 |

> **Not yet published**: Not yet published for Germany: how revenue is counted. Reason: No revenue test appears on the pages read. The value records that none was found, which is not proof that none exists.

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.

<a id="scope"></a>

## 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.

<a id="scope-table"></a>**Scope, producer duties, categories, labelling and targets, Germany and Oregon**

| 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) |

<a id="thresholds"></a>

## Thresholds and exemptions in Germany and Oregon

Every verified threshold Germany and Oregon publish, as each states it.

<a id="thresholds-table"></a>**Verified thresholds in Germany and Oregon**

| 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 |

<a id="b-exemption-small-producer"></a>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.

<a id="b-exemption-covered-product-exemptions"></a>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.

<a id="b-exemption-private-recycling"></a>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.

<a id="rates"></a>

## 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.

> **Not yet published**: Germany: no verified per-kilogram fee schedule is in the dataset yet. 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.

<a id="b-fee-source"></a>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.

<a id="b-rate-or-kraft-paper"></a>Oregon 2027: the category “Kraft Paper” is published at 2.0 cents per pound.

<a id="b-rate-or-hdpe-2-ldpe-4-flexible-and-film-items"></a>Oregon 2027: the category “HDPE (#2)/LDPE (#4) Flexible and Film Items” is published at 12.0 cents per pound.

<a id="b-rate-or-glass-bottles-and-jars-other-containers"></a>Oregon 2027: the category “Glass Bottles and Jars & Other Containers” is published at 0.0 cents per pound.

<a id="deadlines"></a>

## Deadlines in Germany and Oregon

Each verified date, with the period it covers when one is given.

<a id="deadlines-table"></a>**Verified deadlines in Germany and Oregon**

| 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 |

> **Not yet published**: Not yet published for Oregon: the report 2026 supply date. Reason: CAA sets the report date each cycle. The next date was not published on the pages read.

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.

<a id="penalties"></a>

## Penalties in Germany and Oregon

What each side has published; a side without an amount says so.

> **Not yet published**: Not yet published for Germany: penalty amounts. Reason: The fine amounts sit in the statute, which was not readable. Nothing is recorded rather than guessed.

<a id="b-penalty-0"></a>Oregon penalty for failing to register or become a member of a producer responsibility organization: up to $25,000 per day.

<a id="formats"></a>

## Report formats in Germany and Oregon

How the report file for Germany compares with the one for Oregon.

<a id="formats-table"></a>**Report file layouts for Germany and 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 |

<a id="a-format-spec"></a>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).

> **Not yet published**: Oregon: the programme’s own report specification is not yet published. Reason: The detailed Oregon reporting guidance is released only to producers who have signed the CAA PPA. No public layout was found. The layout above is Instica’s working layout.

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.

<a id="choose"></a>

## 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.

<a id="faq"></a>

## Questions about comparing these two programmes

### <a id="q1"></a>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.

### <a id="q2"></a>Do I register in both Germany and Oregon?

Germany requires producers to register. Oregon requires producers to register.

### <a id="q3"></a>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.

### <a id="q4"></a>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.

<a id="estimate"></a>

## How these figures are made

> **Estimate**: Instica measures, estimates and prepares. Every figure on this page is read from a sourced record or computed from one, and each carries its data quality. Converted amounts are approximate and name the exchange rate used. The customer signs and submits each report; Instica never stores regulator login details and never files on your behalf. This page is general information about published rules; confirm your own position with a qualified adviser.

<a id="epr-cite-facts"></a>

## Facts on this page

Each fact is a self-contained sentence with its source. Link to a fact with its anchor.

- <a id="a-regime"></a>Germany: the packaging rules sit in Packaging producer responsibility: register in LUCID, participate packaging subject to system participation in a dual system, and report volumes. [#a-regime](#a-regime)
  Value: Packaging producer responsibility: register in LUCID, participate packaging subject to system participation in a dual system, and report volumes · Source: https://www.verpackungsregister.org/en/system-participation-data-reporting/system-participation · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: you must finance the recycling of your packaging by participating that packaging in a system.
- <a id="a-regulator"></a>Germany: the regulator is Zentrale Stelle Verpackungsregister (ZSVR), which runs the LUCID Packaging Register; competent state authorities enforce. [#a-regulator](#a-regulator)
  Value: Zentrale Stelle Verpackungsregister (ZSVR), which runs the LUCID Packaging Register; competent state authorities enforce · Source: https://www.verpackungsregister.org/en/system-participation-data-reporting/declaration-of-completeness · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: The Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) and the competent state authorities
- <a id="a-obligated"></a>Germany places an obligation on packaging producers. [#a-obligated](#a-obligated)
  Value: yes · Source: https://www.verpackungsregister.org/en/registration/find-out-about-registrations · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: If you are distributing packaged goods in Germany, you have to be registered with the LUCID Packaging Register.
- <a id="a-registration"></a>Germany: producers must register through LUCID Packaging Register (ZSVR). [#a-registration](#a-registration)
  Value: yes · Source: https://www.verpackungsregister.org/en/registration/find-out-about-registrations · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: you must register with the LUCID Packaging Register. Registering is free of charge.
- <a id="a-organisation"></a>Germany organises producer responsibility through more than one producer responsibility organisation; membership is not required. [#a-organisation](#a-organisation)
  Value: several competing organisations · Source: https://www.verpackungsregister.org/en/system-participation-data-reporting/system-participation · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: You can conclude your system participation agreement with the system operator of your choice.
- <a id="a-transfer"></a>Germany allows a producer’s obligation to be transferred to another party. [#a-transfer](#a-transfer)
  Value: yes · Source: https://www.verpackungsregister.org/en/system-participation-data-reporting/system-participation · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: you are required to conclude a system participation agreement with a system operator.
- <a id="a-hierarchy-other"></a>Germany: at the other packaging level the producer hierarchy names the manufacturer or brand owner, manufacturer, importer, first distributor and authorised representative (2026). [#a-hierarchy-other](#a-hierarchy-other)
  Value: manufacturer_brand_owner > manufacturer > importer > first_distributor > authorised_representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- <a id="a-hierarchy-primary"></a>Germany: at the primary packaging level the producer hierarchy names the manufacturer or brand owner, importer, first distributor and authorised representative (2026). [#a-hierarchy-primary](#a-hierarchy-primary)
  Value: manufacturer_brand_owner > importer > first_distributor > authorised_representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- <a id="a-hierarchy-secondary"></a>Germany: at the secondary packaging level the producer hierarchy names the manufacturer or brand owner, importer, first distributor and authorised representative (2026). [#a-hierarchy-secondary](#a-hierarchy-secondary)
  Value: manufacturer_brand_owner > importer > first_distributor > authorised_representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- <a id="a-hierarchy-service"></a>Germany: at the service packaging level the producer hierarchy names the manufacturer or brand owner, manufacturer, importer, first distributor and authorised representative (2026). [#a-hierarchy-service](#a-hierarchy-service)
  Value: manufacturer_brand_owner > manufacturer > importer > first_distributor > authorised_representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- <a id="a-hierarchy-shipping"></a>Germany: at the shipping packaging level the producer hierarchy names the manufacturer or brand owner, packer and shipper, importer, first distributor, online marketplace seller and authorised representative (2026). [#a-hierarchy-shipping](#a-hierarchy-shipping)
  Value: manufacturer_brand_owner > packer_shipper > importer > first_distributor > online_marketplace_seller > authorised_representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- <a id="a-hierarchy-tertiary"></a>Germany: at the tertiary packaging level the producer hierarchy names the manufacturer or brand owner, manufacturer, importer, first distributor and authorised representative (2026). [#a-hierarchy-tertiary](#a-hierarchy-tertiary)
  Value: manufacturer_brand_owner > manufacturer > importer > first_distributor > authorised_representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- <a id="a-threshold-declaration-of-completeness-glass"></a>Germany threshold on tonnage: 80 tonnes; effect: triggers a declaration of completeness. [#a-threshold-declaration-of-completeness-glass](#a-threshold-declaration-of-completeness-glass)
  Value: 80 tonnes · Source: https://www.verpackungsregister.org/en/system-participation-data-reporting/declaration-of-completeness · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Glass: 80 tonnes
- <a id="a-threshold-declaration-of-completeness-paper"></a>Germany threshold on tonnage: 50 tonnes; effect: triggers a declaration of completeness. [#a-threshold-declaration-of-completeness-paper](#a-threshold-declaration-of-completeness-paper)
  Value: 50 tonnes · Source: https://www.verpackungsregister.org/en/system-participation-data-reporting/declaration-of-completeness · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Paper, paperboard, cardboard (PPC) in total: 50 tonnes
- <a id="a-threshold-declaration-of-completeness-lightweight"></a>Germany threshold on tonnage: 30 tonnes; effect: triggers a declaration of completeness. [#a-threshold-declaration-of-completeness-lightweight](#a-threshold-declaration-of-completeness-lightweight)
  Value: 30 tonnes · Source: https://www.verpackungsregister.org/en/system-participation-data-reporting/declaration-of-completeness · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Ferrous metals + aluminium + plastics + beverage cartons + other composites (lightweight packaging) in total: 30 tonnes
- <a id="a-threshold-simplified-reporting"></a>Germany threshold on tonnage: 10 tonnes; effect: reduced duties. [#a-threshold-simplified-reporting](#a-threshold-simplified-reporting)
  Value: 10 tonnes · Source: https://www.verpackungsregister.org/en/system-participation-data-reporting/data-reporting · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: A simplified reporting requirement applies to producers who made available less than 10 tonnes of packaging subject to system participation
- <a id="a-deadline-year-end-volume-report"></a>Germany: report date June 1, 2027, covering calendar year 2026. [#a-deadline-year-end-volume-report](#a-deadline-year-end-volume-report)
  Value: June 1, 2027 · Source: https://www.verpackungsregister.org/en/system-participation-data-reporting/data-reporting · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Year-end volume reports for the previous year (actual volumes) can only be filed up to 1 June.
- <a id="a-deadline-planned-volume-report"></a>Germany: report date December 31, 2026, covering calendar year 2027. [#a-deadline-planned-volume-report](#a-deadline-planned-volume-report)
  Value: December 31, 2026 · Source: https://www.verpackungsregister.org/en/system-participation-data-reporting/data-reporting · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Initial planned volume reports for the following year can only be filed by 31 December of the current year.
- <a id="a-deadline-declaration-of-completeness"></a>Germany: report date May 15, 2027, covering calendar year 2026. [#a-deadline-declaration-of-completeness](#a-deadline-declaration-of-completeness)
  Value: May 15, 2027 · Source: https://www.verpackungsregister.org/en/system-participation-data-reporting/declaration-of-completeness · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: by no later than 15 May of any given year for the previous year.
- <a id="a-scope-materials"></a>Germany: materials covered is paper and card, glass, plastic, steel, aluminium, fibre based composite, other. [#a-scope-materials](#a-scope-materials)
  Value: paper_and_card,glass,plastic,steel,aluminium,fibre_based_composite,other · Source: https://www.verpackungsregister.org/en/registration/find-out-about-registrations · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: There are two different packaging categories: packaging subject to system participation and packaging not subject to system participation.
- <a id="a-scope-products"></a>Germany: product classes covered is primary packaging, secondary packaging, shipment packaging, tertiary packaging, reusable packaging. [#a-scope-products](#a-scope-products)
  Value: primary_packaging,secondary_packaging,shipment_packaging,tertiary_packaging,reusable_packaging · Source: https://www.verpackungsregister.org/en/registration/find-out-about-registrations · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: There are two different packaging categories: packaging subject to system participation and packaging not subject to system participation.
- <a id="a-scope-channels"></a>Germany: sales channels addressed is retail, wholesale, online, online marketplace. [#a-scope-channels](#a-scope-channels)
  Value: retail,wholesale,online,online_marketplace · Source: https://www.verpackungsregister.org/en/registration/find-out-about-registrations · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: There are two different packaging categories: packaging subject to system participation and packaging not subject to system participation.
- <a id="a-scope-ph-primary"></a>Germany: producer duty: primary packaging is manufacturer_brand_owner; importer; first_distributor; authorised_representative. [#a-scope-ph-primary](#a-scope-ph-primary)
  Value: manufacturer or brand owner, importer, first distributor, and authorized representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- <a id="a-scope-ph-secondary"></a>Germany: producer duty: secondary packaging is manufacturer_brand_owner; importer; first_distributor; authorised_representative. [#a-scope-ph-secondary](#a-scope-ph-secondary)
  Value: manufacturer or brand owner, importer, first distributor, and authorized representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- <a id="a-scope-ph-tertiary"></a>Germany: producer duty: tertiary packaging is manufacturer_brand_owner; manufacturer; importer; first_distributor; authorised_representative. [#a-scope-ph-tertiary](#a-scope-ph-tertiary)
  Value: manufacturer or brand owner, manufacturer, importer, first distributor, and authorized representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- <a id="a-scope-ph-shipping"></a>Germany: producer duty: shipping packaging is manufacturer_brand_owner; packer_shipper; importer; first_distributor; online_marketplace_seller; authorised_representative. [#a-scope-ph-shipping](#a-scope-ph-shipping)
  Value: manufacturer or brand owner, packer or shipper, importer, first distributor, seller on an online marketplace, and authorized representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- <a id="a-scope-ph-service"></a>Germany: producer duty: service packaging is manufacturer_brand_owner; manufacturer; importer; first_distributor; authorised_representative. [#a-scope-ph-service](#a-scope-ph-service)
  Value: manufacturer or brand owner, manufacturer, importer, first distributor, and authorized representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- <a id="a-scope-ph-other"></a>Germany: producer duty: other packaging is manufacturer_brand_owner; manufacturer; importer; first_distributor; authorised_representative. [#a-scope-ph-other](#a-scope-ph-other)
  Value: manufacturer or brand owner, manufacturer, importer, first distributor, and authorized representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- <a id="b-regime"></a>Oregon: the packaging rules sit in Oregon Recycling Modernization Act, ORS 459A.860 to 459A.975 (SB 582 of 2021). [#b-regime](#b-regime)
  Value: Oregon Recycling Modernization Act, ORS 459A.860 to 459A.975 (SB 582 of 2021) · Source: https://www.oregon.gov/deq/recycling/pages/producers-of-covered-products.aspx · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: producers of products covered under Oregon's Recycling Modernization Act (packaging, paper, and food serviceware)
- <a id="b-regulator"></a>Oregon: the regulator is Oregon Department of Environmental Quality (DEQ). [#b-regulator](#b-regulator)
  Value: Oregon Department of Environmental Quality (DEQ) · Source: https://www.oregon.gov/deq/recycling/pages/producers-of-covered-products.aspx · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Circular Action Alliance, at present, is Oregon's only approved Producer Responsibility Organization
- <a id="b-obligated"></a>Oregon places an obligation on packaging producers. [#b-obligated](#b-obligated)
  Value: yes · Source: https://oregon.public.law/statutes/ors_459A.869 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: each producer must register with and be a member of a producer responsibility organization that administers a producer responsibility program
- <a id="b-registration"></a>Oregon: producers must register through Circular Action Alliance producer portal (PRO registration); DEQ holds no separate producer registry. [#b-registration](#b-registration)
  Value: yes · Source: https://www.oregon.gov/deq/recycling/pages/producers-of-covered-products.aspx · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: In order to access CAA's data reporting portal, producers must first sign the Producer Participant Agreement with CAA
- <a id="b-organisation"></a>Oregon organises producer responsibility through a single producer responsibility organisation: Circular Action Alliance; membership is required. [#b-organisation](#b-organisation)
  Value: one producer responsibility organisation · Source: https://www.oregon.gov/deq/recycling/pages/producers-of-covered-products.aspx · Retrieved: November 5, 2026 · Status: verified
  Verbatim quote: Circular Action Alliance, at present, is Oregon's only approved Producer Responsibility Organization
- <a id="b-transfer"></a>Oregon allows a producer’s obligation to be transferred to another party. [#b-transfer](#b-transfer)
  Value: yes · Source: https://oregon.public.law/statutes/ors_459A.869 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: A producer is not required to be a member of a producer responsibility organization if, for all covered product the producer sells
- <a id="b-revenue-scope"></a>Oregon measures revenue as organisation gross revenue in USD, over the fiscal year. [#b-revenue-scope](#b-revenue-scope)
  Value: organisation_gross_revenue · Source: https://oregon.public.law/statutes/ors_459A.863 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Has a gross revenue of less than $5 million for the organization's most recent fiscal year
- <a id="b-hierarchy-other"></a>Oregon: at the other packaging level the producer hierarchy names the first distributor (2025). [#b-hierarchy-other](#b-hierarchy-other)
  Value: first distributor · Source: https://oregon.public.law/statutes/ors_459A.866 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: the producer of the packaging is the person that manufactures the packaged item
- <a id="b-hierarchy-primary"></a>Oregon: at the primary packaging level the producer hierarchy names the manufacturer or brand owner, brand licensee and importer (2025). [#b-hierarchy-primary](#b-hierarchy-primary)
  Value: manufacturer_brand_owner > licensee > importer · Source: https://oregon.public.law/statutes/ors_459A.866 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: the producer of the packaging is the person that manufactures the packaged item
- <a id="b-hierarchy-secondary"></a>Oregon: at the secondary packaging level the producer hierarchy names the manufacturer or brand owner, brand licensee and importer (2025). [#b-hierarchy-secondary](#b-hierarchy-secondary)
  Value: manufacturer_brand_owner > licensee > importer · Source: https://oregon.public.law/statutes/ors_459A.866 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: the producer of the packaging is the person that manufactures the packaged item
- <a id="b-hierarchy-service"></a>Oregon: at the service packaging level the producer hierarchy names the first distributor (2025). [#b-hierarchy-service](#b-hierarchy-service)
  Value: first distributor · Source: https://oregon.public.law/statutes/ors_459A.866 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: the producer of the packaging is the person that manufactures the packaged item
- <a id="b-hierarchy-shipping"></a>Oregon: at the shipping packaging level the producer hierarchy names the packer and shipper (2025). [#b-hierarchy-shipping](#b-hierarchy-shipping)
  Value: packer or shipper · Source: https://oregon.public.law/statutes/ors_459A.866 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: the producer of the packaging is the person that manufactures the packaged item
- <a id="b-hierarchy-tertiary"></a>Oregon: at the tertiary packaging level the producer hierarchy names the first distributor (2025). [#b-hierarchy-tertiary](#b-hierarchy-tertiary)
  Value: first distributor · Source: https://oregon.public.law/statutes/ors_459A.866 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: the producer of the packaging is the person that manufactures the packaged item
- <a id="b-threshold-small-producer-revenue"></a>Oregon threshold on revenue: $5,000,000; effect: exempt below the threshold. [#b-threshold-small-producer-revenue](#b-threshold-small-producer-revenue)
  Value: $5,000,000 · Source: https://oregon.public.law/statutes/ors_459A.863 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Has a gross revenue of less than $5 million for the organization's most recent fiscal year
- <a id="b-threshold-small-producer-tonnage"></a>Oregon threshold on tonnage: 1 metric ton; effect: exempt below the threshold. [#b-threshold-small-producer-tonnage](#b-threshold-small-producer-tonnage)
  Value: 1 metric ton · Source: https://oregon.public.law/statutes/ors_459A.863 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Sold in or into Oregon less than one metric ton of covered products for use in this state in the most recent calendar year
- <a id="b-threshold-small-beverage-manufacturer-tonnage"></a>Oregon threshold on tonnage: 5 metric tons; effect: exempt below the threshold. [#b-threshold-small-beverage-manufacturer-tonnage](#b-threshold-small-beverage-manufacturer-tonnage)
  Value: 5 metric tons · Source: https://oregon.public.law/statutes/ors_459A.863 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: that sold in or into Oregon less than five metric tons of covered products
- <a id="b-threshold-uniform-membership-fee-band"></a>Oregon threshold on revenue: $10,000,000; effect: flat fee band. [#b-threshold-uniform-membership-fee-band](#b-threshold-uniform-membership-fee-band)
  Value: $10,000,000 · Source: https://oregon.public.law/statutes/ors_459A.884 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: a producer responsibility organization shall establish uniform membership fees for members that had a gross revenue of less than $10 million
- 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. [#b-exemption-small-producer](#b-exemption-small-producer)
  Value: small_producer · Source: https://oregon.public.law/statutes/ors_459A.872 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: A small producer is exempt from the requirement to be a member of a producer responsibility organization
- 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. [#b-exemption-covered-product-exemptions](#b-exemption-covered-product-exemptions)
  Value: covered_product_exemptions · Source: https://www.oregon.gov/deq/recycling/pages/rma-exemptions.aspx · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Covered product exemptions, meanwhile, are product-specific exemptions that exclude a given type of packaging
- 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. [#b-exemption-private-recycling](#b-exemption-private-recycling)
  Value: private_recycling · Source: https://www.oregon.gov/deq/recycling/pages/rma-exemptions.aspx · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: The latest window for producers to submit claims for this exemption was Jan. 6 – March 31, 2026
- <a id="b-deadline-report-2025-supply"></a>Oregon: report date May 31, 2026, covering calendar year 2025. [#b-deadline-report-2025-supply](#b-deadline-report-2025-supply)
  Value: May 31, 2026 · Source: https://circularactionalliance.org/producer-reporting · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Oregon's 2026 Report is due May 31, 2026, based on the 2025 Data Year.
- <a id="b-deadline-pro-fee-charging-start"></a>Oregon: other date July 1, 2025. [#b-deadline-pro-fee-charging-start](#b-deadline-pro-fee-charging-start)
  Value: July 1, 2025 · Source: https://www.oregon.gov/deq/recycling/pages/producers-of-covered-products.aspx · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: was allowed to begin charging fees from member producers on July 1, 2025
- <a id="b-deadline-private-recycling-claim-window-2028-fee-year"></a>Oregon: other date January 1, 2027. [#b-deadline-private-recycling-claim-window-2028-fee-year](#b-deadline-private-recycling-claim-window-2028-fee-year)
  Value: January 1, 2027 · Source: https://www.oregon.gov/deq/recycling/pages/rma-exemptions.aspx · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: The next claims window will open in Jan. 2027.
- <a id="b-deadline-large-producer-impact-disclosure"></a>Oregon: report date December 31, 2026. [#b-deadline-large-producer-impact-disclosure](#b-deadline-large-producer-impact-disclosure)
  Value: December 31, 2026 · Source: https://www.oregon.gov/deq/recycling/pages/producers-of-covered-products.aspx · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Large producer first impact disclosure date of Dec. 31, 2026
- Oregon penalty for failing to register or become a member of a producer responsibility organization: up to $25,000 per day. [#b-penalty-0](#b-penalty-0)
  Value: $25,000 · Source: https://www.oregon.gov/deq/recycling/pages/producers-of-covered-products.aspx · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: is a Class 1 violation that can result in fines of up to $25,000 per day.
- <a id="b-scope-materials"></a>Oregon: materials covered is packaging, printing and writing paper, food serviceware. [#b-scope-materials](#b-scope-materials)
  Value: packaging,printing_and_writing_paper,food_serviceware · Source: https://oregon.public.law/statutes/ors_459A.863 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: "Covered product" means: (A) Packaging; (B) Printing and writing paper; and (C) Food serviceware.
- <a id="b-scope-products"></a>Oregon: product classes covered is packaging, printing and writing paper, food serviceware. [#b-scope-products](#b-scope-products)
  Value: packaging,printing_and_writing_paper,food_serviceware · Source: https://oregon.public.law/statutes/ors_459A.863 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: "Covered product" means: (A) Packaging; (B) Printing and writing paper; and (C) Food serviceware.
- <a id="b-scope-excluded"></a>Oregon: excluded from scope is 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. [#b-scope-excluded](#b-scope-excluded)
  Value: 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 · Source: https://oregon.public.law/statutes/ors_459A.863 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: "Covered product" means: (A) Packaging; (B) Printing and writing paper; and (C) Food serviceware.
- <a id="b-scope-channels"></a>Oregon: sales channels addressed is physical retail, remote sale, other distribution. [#b-scope-channels](#b-scope-channels)
  Value: physical_retail,remote_sale,other_distribution · Source: https://oregon.public.law/statutes/ors_459A.863 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: "Covered product" means: (A) Packaging; (B) Printing and writing paper; and (C) Food serviceware.
- <a id="b-scope-ph-primary"></a>Oregon: producer duty: primary packaging is manufacturer_brand_owner; licensee; importer. [#b-scope-ph-primary](#b-scope-ph-primary)
  Value: manufacturer or brand owner, licensee, and importer · Source: https://oregon.public.law/statutes/ors_459A.866 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: the producer of the packaging is the person that manufactures the packaged item
- <a id="b-scope-ph-secondary"></a>Oregon: producer duty: secondary packaging is manufacturer_brand_owner; licensee; importer. [#b-scope-ph-secondary](#b-scope-ph-secondary)
  Value: manufacturer or brand owner, licensee, and importer · Source: https://oregon.public.law/statutes/ors_459A.866 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: the producer of the packaging is the person that manufactures the packaged item
- <a id="b-scope-ph-tertiary"></a>Oregon: producer duty: tertiary packaging is first_distributor. [#b-scope-ph-tertiary](#b-scope-ph-tertiary)
  Value: first distributor · Source: https://oregon.public.law/statutes/ors_459A.866 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: the producer of the packaging is the person that manufactures the packaged item
- <a id="b-scope-ph-shipping"></a>Oregon: producer duty: shipping packaging is packer_shipper. [#b-scope-ph-shipping](#b-scope-ph-shipping)
  Value: packer or shipper · Source: https://oregon.public.law/statutes/ors_459A.866 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: the producer of the packaging is the person that manufactures the packaged item
- <a id="b-scope-ph-service"></a>Oregon: producer duty: service packaging is first_distributor. [#b-scope-ph-service](#b-scope-ph-service)
  Value: first distributor · Source: https://oregon.public.law/statutes/ors_459A.866 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: the producer of the packaging is the person that manufactures the packaged item
- <a id="b-scope-ph-other"></a>Oregon: producer duty: other packaging is first_distributor. [#b-scope-ph-other](#b-scope-ph-other)
  Value: first distributor · Source: https://oregon.public.law/statutes/ors_459A.866 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: the producer of the packaging is the person that manufactures the packaged item
- <a id="b-scope-categories"></a>Oregon: reporting categories is 60, covered material type by material class. [#b-scope-categories](#b-scope-categories)
  Value: 60 · Source: https://circularactionalliance.org/s/OR-2026-Fee-Schedule-Public.pdf · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Materials labeled N/A in the following table are not accepted on either the USCL or PRO Recycling Acceptance List.
- <a id="b-scope-targets"></a>Oregon: published targets is 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. [#b-scope-targets](#b-scope-targets)
  Value: 3 · Source: https://oregon.public.law/statutes/ors_459A.926 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: At least 25 percent by calendar year 2028 and in each subsequent year
- <a id="b-scope-ex1"></a>Oregon: exemption 1 is 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. [#b-scope-ex1](#b-scope-ex1)
  Value: 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. · Source: https://oregon.public.law/statutes/ors_459A.872 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: A small producer is exempt from the requirement to be a member of a producer responsibility organization
- <a id="b-scope-ex2"></a>Oregon: exemption 2 is 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. [#b-scope-ex2](#b-scope-ex2)
  Value: 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. · Source: https://www.oregon.gov/deq/recycling/pages/rma-exemptions.aspx · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Covered product exemptions, meanwhile, are product-specific exemptions that exclude a given type of packaging
- <a id="b-scope-ex3"></a>Oregon: exemption 3 is 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). [#b-scope-ex3](#b-scope-ex3)
  Value: 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. · Source: https://www.oregon.gov/deq/recycling/pages/rma-exemptions.aspx · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: The latest window for producers to submit claims for this exemption was Jan. 6 – March 31, 2026
- Both programmes require a producer to register, in Germany and in Oregon. [#calc-registration](#calc-registration)
  Value: same · Source: https://www.verpackungsregister.org/en/registration/find-out-about-registrations · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: you must register with the LUCID Packaging Register. Registering is free of charge.
- 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. [#calc-report-date](#calc-report-date)
  Value: DE days · Source: https://www.verpackungsregister.org/en/system-participation-data-reporting/declaration-of-completeness · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: by no later than 15 May of any given year for the previous year.
- 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. [#b-fee-source](#b-fee-source)
  Value: CAA Oregon 2027 Fee Schedule (public) · Source: https://circularactionalliance.org/s/OR-2027FeeSchedule_100126.pdf · Retrieved: October 22, 2026 · Status: verified
  Verbatim quote: 2027 Oregon Producer Fees Schedule Fees for Program Year 2027
- Oregon 2027: the category “Kraft Paper” is published at 2.0 cents per pound. [#b-rate-or-kraft-paper](#b-rate-or-kraft-paper)
  Value: 2.0 cents_per_lb · Source: https://circularactionalliance.org/s/OR-2027FeeSchedule_100126.pdf · Retrieved: October 22, 2026 · Status: verified
  Verbatim quote: Kraft Paper USCL 0.07 0.00 -0.05 0.02
- Oregon 2027: the category “HDPE (#2)/LDPE (#4) Flexible and Film Items” is published at 12.0 cents per pound. [#b-rate-or-hdpe-2-ldpe-4-flexible-and-film-items](#b-rate-or-hdpe-2-ldpe-4-flexible-and-film-items)
  Value: 12.0 cents_per_lb · Source: https://circularactionalliance.org/s/OR-2027FeeSchedule_100126.pdf · Retrieved: October 22, 2026 · Status: verified
  Verbatim quote: HDPE (#2)/LDPE (#4) Flexible and Film Items PRO 0.29 0.00 -0.17 0.12
- Oregon 2027: the category “Glass Bottles and Jars & Other Containers” is published at 0.0 cents per pound. [#b-rate-or-glass-bottles-and-jars-other-containers](#b-rate-or-glass-bottles-and-jars-other-containers)
  Value: 0.0 cents_per_lb · Source: https://circularactionalliance.org/s/OR-2027FeeSchedule_100126.pdf · Retrieved: October 22, 2026 · Status: verified
  Verbatim quote: Glass Bottles and Jars & Other Containers PRO 0.04 -0.01 -0.03 0.00
- 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). [#a-format-spec](#a-format-spec)
  Value: XML producer volume report with elements VersionNoInterface, PackagingTypeCode, TypeOfReportCode, ReportingPeriodFrom, ReportingPeriodTo and one SystemOperator with its SystemOperatorID and a Material list (MaterialCode, Mass). · Source: https://www.verpackungsregister.org/fileadmin/files/LUCID/Anleitung_XML_Datenmeldung_EN.pdf · Retrieved: September 30, 2026 · Status: verified
  Verbatim quote: Mass: packaging material mass in kg to the third decimal place without thousands separators (decimal place demarcated with comma).

## Related pages

### Part of

- [Germany EPR](https://instica.com/epr/germany)

### Explore packaging EPR

- [EPR Europe](https://instica.com/epr/europe)

### More for this jurisdiction

- [Oregon EPR 2027](https://instica.com/epr/oregon)

### Related pages

- [Germany vs United Kingdom EPR: Rules Compared](https://instica.com/epr/compare/germany-vs-uk)
- [Germany vs Washington EPR: Rules Compared](https://instica.com/epr/compare/germany-vs-washington)
- [Italy vs Oregon EPR: Rules Compared](https://instica.com/epr/compare/italy-vs-oregon)
- [Italy vs United Kingdom EPR: Rules Compared](https://instica.com/epr/compare/italy-vs-uk)
- [Italy vs Washington EPR: Rules Compared](https://instica.com/epr/compare/italy-vs-washington)
- [Manitoba vs Québec EPR: Rules Compared](https://instica.com/epr/compare/manitoba-vs-quebec)

## Sources

1. verpackungsregister.org: system participation (https://www.verpackungsregister.org/en/system-participation-data-reporting/system-participation), Retrieved: September 29, 2026, Status: verified
   > you must finance the recycling of your packaging by participating that packaging in a system.
2. verpackungsregister.org: declaration of completeness (https://www.verpackungsregister.org/en/system-participation-data-reporting/declaration-of-completeness), Retrieved: September 29, 2026, Status: verified
   > The Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) and the competent state authorities
3. verpackungsregister.org: find out about registrations (https://www.verpackungsregister.org/en/registration/find-out-about-registrations), Retrieved: September 29, 2026, Status: verified
   > If you are distributing packaged goods in Germany, you have to be registered with the LUCID Packaging Register.
4. verpackungsregister.org: find out about registrations (https://www.verpackungsregister.org/en/registration/find-out-about-registrations), Retrieved: September 29, 2026, Status: verified
   > you must register with the LUCID Packaging Register. Registering is free of charge.
5. verpackungsregister.org: system participation (https://www.verpackungsregister.org/en/system-participation-data-reporting/system-participation), Retrieved: September 29, 2026, Status: verified
   > You can conclude your system participation agreement with the system operator of your choice.
6. verpackungsregister.org: system participation (https://www.verpackungsregister.org/en/system-participation-data-reporting/system-participation), Retrieved: September 29, 2026, Status: verified
   > you are required to conclude a system participation agreement with a system operator.
7. verpackungsregister.org: distinguishing between manufacturers producers (https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers), Retrieved: November 4, 2026, Status: verified
   > 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
8. verpackungsregister.org: declaration of completeness (https://www.verpackungsregister.org/en/system-participation-data-reporting/declaration-of-completeness), Retrieved: September 29, 2026, Status: verified
   > Glass: 80 tonnes
9. verpackungsregister.org: declaration of completeness (https://www.verpackungsregister.org/en/system-participation-data-reporting/declaration-of-completeness), Retrieved: September 29, 2026, Status: verified
   > Paper, paperboard, cardboard (PPC) in total: 50 tonnes
10. verpackungsregister.org: declaration of completeness (https://www.verpackungsregister.org/en/system-participation-data-reporting/declaration-of-completeness), Retrieved: September 29, 2026, Status: verified
   > Ferrous metals + aluminium + plastics + beverage cartons + other composites (lightweight packaging) in total: 30 tonnes
11. verpackungsregister.org: data reporting (https://www.verpackungsregister.org/en/system-participation-data-reporting/data-reporting), Retrieved: September 29, 2026, Status: verified
   > A simplified reporting requirement applies to producers who made available less than 10 tonnes of packaging subject to system participation
12. verpackungsregister.org: data reporting (https://www.verpackungsregister.org/en/system-participation-data-reporting/data-reporting), Retrieved: September 29, 2026, Status: verified
   > Year-end volume reports for the previous year (actual volumes) can only be filed up to 1 June.
13. verpackungsregister.org: data reporting (https://www.verpackungsregister.org/en/system-participation-data-reporting/data-reporting), Retrieved: September 29, 2026, Status: verified
   > Initial planned volume reports for the following year can only be filed by 31 December of the current year.
14. verpackungsregister.org: declaration of completeness (https://www.verpackungsregister.org/en/system-participation-data-reporting/declaration-of-completeness), Retrieved: September 29, 2026, Status: verified
   > by no later than 15 May of any given year for the previous year.
15. verpackungsregister.org: find out about registrations (https://www.verpackungsregister.org/en/registration/find-out-about-registrations), Retrieved: September 29, 2026, Status: verified
   > There are two different packaging categories: packaging subject to system participation and packaging not subject to system participation.
16. oregon.gov: producers of covered products (https://www.oregon.gov/deq/recycling/pages/producers-of-covered-products.aspx), Retrieved: September 29, 2026, Status: verified
   > producers of products covered under Oregon's Recycling Modernization Act (packaging, paper, and food serviceware)
17. oregon.gov: producers of covered products (https://www.oregon.gov/deq/recycling/pages/producers-of-covered-products.aspx), Retrieved: September 29, 2026, Status: verified
   > Circular Action Alliance, at present, is Oregon's only approved Producer Responsibility Organization
18. oregon.public.law: ors 459A.869 (https://oregon.public.law/statutes/ors_459A.869), Retrieved: September 29, 2026, Status: verified
   > each producer must register with and be a member of a producer responsibility organization that administers a producer responsibility program
19. oregon.gov: producers of covered products (https://www.oregon.gov/deq/recycling/pages/producers-of-covered-products.aspx), Retrieved: September 29, 2026, Status: verified
   > In order to access CAA's data reporting portal, producers must first sign the Producer Participant Agreement with CAA
20. oregon.public.law: ors 459A.869 (https://oregon.public.law/statutes/ors_459A.869), Retrieved: September 29, 2026, Status: verified
   > A producer is not required to be a member of a producer responsibility organization if, for all covered product the producer sells
21. oregon.public.law: ors 459A.863 (https://oregon.public.law/statutes/ors_459A.863), Retrieved: September 29, 2026, Status: verified
   > Has a gross revenue of less than $5 million for the organization's most recent fiscal year
22. oregon.public.law: ors 459A.866 (https://oregon.public.law/statutes/ors_459A.866), Retrieved: September 29, 2026, Status: verified
   > the producer of the packaging is the person that manufactures the packaged item
23. oregon.public.law: ors 459A.863 (https://oregon.public.law/statutes/ors_459A.863), Retrieved: September 29, 2026, Status: verified
   > Sold in or into Oregon less than one metric ton of covered products for use in this state in the most recent calendar year
24. oregon.public.law: ors 459A.863 (https://oregon.public.law/statutes/ors_459A.863), Retrieved: September 29, 2026, Status: verified
   > that sold in or into Oregon less than five metric tons of covered products
25. oregon.public.law: ors 459A.884 (https://oregon.public.law/statutes/ors_459A.884), Retrieved: September 29, 2026, Status: verified
   > a producer responsibility organization shall establish uniform membership fees for members that had a gross revenue of less than $10 million
26. oregon.public.law: ors 459A.872 (https://oregon.public.law/statutes/ors_459A.872), Retrieved: September 29, 2026, Status: verified
   > A small producer is exempt from the requirement to be a member of a producer responsibility organization
27. oregon.gov: rma exemptions (https://www.oregon.gov/deq/recycling/pages/rma-exemptions.aspx), Retrieved: September 29, 2026, Status: verified
   > Covered product exemptions, meanwhile, are product-specific exemptions that exclude a given type of packaging
28. oregon.gov: rma exemptions (https://www.oregon.gov/deq/recycling/pages/rma-exemptions.aspx), Retrieved: September 29, 2026, Status: verified
   > The latest window for producers to submit claims for this exemption was Jan. 6 – March 31, 2026
29. circularactionalliance.org: producer reporting (https://circularactionalliance.org/producer-reporting), Retrieved: September 29, 2026, Status: verified
   > Oregon's 2026 Report is due May 31, 2026, based on the 2025 Data Year.
30. oregon.gov: producers of covered products (https://www.oregon.gov/deq/recycling/pages/producers-of-covered-products.aspx), Retrieved: September 29, 2026, Status: verified
   > was allowed to begin charging fees from member producers on July 1, 2025
31. oregon.gov: rma exemptions (https://www.oregon.gov/deq/recycling/pages/rma-exemptions.aspx), Retrieved: September 29, 2026, Status: verified
   > The next claims window will open in Jan. 2027.
32. oregon.gov: producers of covered products (https://www.oregon.gov/deq/recycling/pages/producers-of-covered-products.aspx), Retrieved: September 29, 2026, Status: verified
   > Large producer first impact disclosure date of Dec. 31, 2026
33. oregon.gov: producers of covered products (https://www.oregon.gov/deq/recycling/pages/producers-of-covered-products.aspx), Retrieved: September 29, 2026, Status: verified
   > is a Class 1 violation that can result in fines of up to $25,000 per day.
34. oregon.public.law: ors 459A.863 (https://oregon.public.law/statutes/ors_459A.863), Retrieved: September 29, 2026, Status: verified
   > "Covered product" means: (A) Packaging; (B) Printing and writing paper; and (C) Food serviceware.
35. circularactionalliance.org: OR 2026 Fee Schedule Public (https://circularactionalliance.org/s/OR-2026-Fee-Schedule-Public.pdf), Retrieved: September 29, 2026, Status: verified
   > Materials labeled N/A in the following table are not accepted on either the USCL or PRO Recycling Acceptance List.
36. oregon.public.law: ors 459A.926 (https://oregon.public.law/statutes/ors_459A.926), Retrieved: September 29, 2026, Status: verified
   > At least 25 percent by calendar year 2028 and in each subsequent year
37. circularactionalliance.org: OR 2027FeeSchedule 100126 (https://circularactionalliance.org/s/OR-2027FeeSchedule_100126.pdf), Retrieved: October 22, 2026, Status: verified
   > 2027 Oregon Producer Fees Schedule Fees for Program Year 2027
38. circularactionalliance.org: OR 2027FeeSchedule 100126 (https://circularactionalliance.org/s/OR-2027FeeSchedule_100126.pdf), Retrieved: October 22, 2026, Status: verified
   > Kraft Paper USCL 0.07 0.00 -0.05 0.02
39. circularactionalliance.org: OR 2027FeeSchedule 100126 (https://circularactionalliance.org/s/OR-2027FeeSchedule_100126.pdf), Retrieved: October 22, 2026, Status: verified
   > HDPE (#2)/LDPE (#4) Flexible and Film Items PRO 0.29 0.00 -0.17 0.12
40. circularactionalliance.org: OR 2027FeeSchedule 100126 (https://circularactionalliance.org/s/OR-2027FeeSchedule_100126.pdf), Retrieved: October 22, 2026, Status: verified
   > Glass Bottles and Jars & Other Containers PRO 0.04 -0.01 -0.03 0.00
41. verpackungsregister.org: Anleitung XML Datenmeldung EN (https://www.verpackungsregister.org/fileadmin/files/LUCID/Anleitung_XML_Datenmeldung_EN.pdf), Retrieved: September 30, 2026, Status: verified
   > Mass: packaging material mass in kg to the third decimal place without thousands separators (decimal place demarcated with comma).

## Cite this page

Instica, “Germany vs Oregon EPR: Rules Compared”, https://instica.com/epr/compare/germany-vs-oregon, last verified 2026-11-05, dataset v1-281284b7e7c1, CC-BY-4.0.

- Canonical URL: https://instica.com/epr/compare/germany-vs-oregon
- Last verified: November 5, 2026
- Last changed: November 5, 2026
- Dataset version: v1-281284b7e7c1
- Licence: Reuse is allowed under CC-BY-4.0 with credit to Instica and a link to this page.
- Machine-readable versions: https://instica.com/epr/compare/germany-vs-oregon.md · https://instica.com/epr/compare/germany-vs-oregon.json