Ontario vs Oregon EPR: Rules Compared
Last verified
Ontario and Oregon both run packaging EPR, but the rules differ. Ontario exempts only producers below the lower revenue floor, CA$2,000,000 against $5,000,000 in Oregon. Both set the lowest weight exemption at 1 tonne. Both require producers to register. Both programmes set their first annual report for May 31.
Ontario and Oregon side by side
4 of 9 rows have a verified figure on each side of Ontario 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 | Ontario | Oregon | Stricter |
|---|---|---|---|
| Registration duty | Required | Required | Same |
| Producer organisation | more than one producer responsibility organisation | one producer responsibility organisation | Not comparable |
| Lowest revenue exemption | CA$2,000,000 | $5,000,000 | Ontario |
| Lowest weight exemption | 1 tonne | 1 tonne | Same |
| First annual report date | May 31 | May 31 | Same |
| Published penalties | not yet published | 1 published | Not comparable |
| Report file | csv | 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 |
The lowest revenue exemption is CA$2,000,000 in Ontario and $5,000,000 in Oregon (CA$6,989,000 at the Bank of Canada 2025 annual average rate). Ontario therefore reaches smaller sellers: a business with revenue between the two lines is exempt in Oregon but still in scope in Ontario.
The lowest weight exemption is the same on both sides: 1 tonne of packaging.
Both programmes require a producer to register, in Ontario and in Oregon.
The first annual report date is the same on both sides, May 31.
Who runs the programme in Ontario and Oregon
Who collects and who the producer files with, in Ontario and then Oregon.
| Aspect | Ontario | Oregon |
|---|---|---|
| Regime | Full producer responsibility for Blue Box material (packaging, paper products, packaging-like products) under the Blue Box Regulation | Oregon Recycling Modernization Act, ORS 459A.860 to 459A.975 (SB 582 of 2021) |
| Regulator | Resource Productivity and Recovery Authority (RPRA) | Oregon Department of Environmental Quality (DEQ) |
| Producers obligated | Yes | Yes |
| Registration | Required, RPRA Registry | 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 | regional revenue, CAD, calendar year | organisation gross revenue, USD, fiscal year |
| Who counts as the producer | other: brand owner, importer, seller, online marketplace; primary: brand owner, importer, seller, online marketplace; secondary: brand owner, importer, seller, online marketplace; service: seller; shipping: brand owner, importer, seller, online marketplace; tertiary: brand owner, importer, seller, online marketplace | 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. Ontario 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 Ontario and Oregon cover, side by side
Each row below is one published feature of the two programmes; a cell reads “not yet published” when Ontario or Oregon has no verified entry for it in the dataset.
| Aspect | Ontario | Oregon |
|---|---|---|
| Materials covered | paper, glass, metal, plastic, other | packaging, printing and writing paper, food serviceware |
| Product classes covered | primary packaging, secondary packaging, shipment packaging, other | packaging, printing and writing paper, food serviceware |
| Excluded from scope | producers under revenue exemption, newspaper producers for collection management and promotion | 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 |
| Sales channels addressed | retail, wholesale, online, online marketplace | physical retail, remote sale, other distribution |
| Producer duty: primary packaging | brand_owner; importer; seller; marketplace | manufacturer_brand_owner; licensee; importer |
| Producer duty: secondary packaging | brand_owner; importer; seller; marketplace | manufacturer_brand_owner; licensee; importer |
| Producer duty: tertiary packaging | brand_owner; importer; seller; marketplace | first_distributor |
| Producer duty: shipping packaging | brand_owner; importer; seller; marketplace | packer_shipper |
| Producer duty: service packaging | seller | first_distributor |
| Producer duty: other packaging | brand_owner; importer; seller; marketplace | first_distributor |
| Reporting categories | 7, material category | 60, covered material type by material class |
| Published targets | paper_management_requirement 80 by 2027-12-31; rigid_plastic_management_requirement 50 by 2027-12-31; flexible_plastic_management_requirement 10 by 2027-12-31; glass_management_requirement 75 by 2027-12-31; metal_management_requirement 67 by 2027-12-31; beverage_container_management_requirement 75 by 2027-12-31 | 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 | Producers with gross annual Ontario revenue under 2,000,000 dollars are exempt from all producer requirements. | 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 | Producers above the revenue level but below the per-category supply weights are exempt from collection, management and promotion and education, but still register and report. | 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 | Producers whose newspaper supply is more than 70 percent of their total Blue Box weight are exempt from collection, management and promotion and education. | 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 Ontario and Oregon
Every verified threshold Ontario and Oregon publish, as each states it.
| Place | Measure | Amount | Effect | Basis as published |
|---|---|---|---|---|
| Ontario | revenue | CA$2,000,000 | exempt below | gross annual Ontario revenue from products and services |
| Ontario | packaging tonnage | 9 tonnes | exempt below | paper supplied in Ontario per year (9,000 kg) |
| Ontario | packaging tonnage | 2 tonnes | exempt below | rigid plastic supplied in Ontario per year (2,000 kg) |
| Ontario | packaging tonnage | 2 tonnes | exempt below | flexible plastic supplied in Ontario per year (2,000 kg) |
| Ontario | packaging tonnage | 1 tonne | exempt below | glass supplied in Ontario per year (1,000 kg) |
| Ontario | packaging tonnage | 1 tonne | exempt below | metal supplied in Ontario per year (1,000 kg) |
| Ontario | packaging tonnage | 1 tonne | exempt below | beverage containers supplied in Ontario per year (1,000 kg) |
| 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 |
Ontario exemption: Producers with gross annual Ontario revenue under 2,000,000 dollars are exempt from all producer requirements. It does not have to be applied for.
Ontario exemption: Producers above the revenue level but below the per-category supply weights are exempt from collection, management and promotion and education, but still register and report. It does not have to be applied for.
Ontario exemption: Producers whose newspaper supply is more than 70 percent of their total Blue Box weight are exempt from collection, management and promotion and education. It does not have to be applied for.
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.
The lowest revenue exemption is CA$2,000,000 in Ontario and $5,000,000 in Oregon (CA$6,989,000 at the Bank of Canada 2025 annual average rate). Ontario therefore reaches smaller sellers: a business with revenue between the two lines is exempt in Oregon but still in scope in Ontario.
The lowest weight exemption is the same on both sides: 1 tonne of packaging.
Fees per kilogram for shared materials
Oregon publishes per-kilogram rates in the dataset; Ontario does not. The rows therefore show Oregon only. Until both sides publish per-kilogram rates for the same material class, a fee comparison between Ontario 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 Ontario and Oregon
Each verified date, with the period it covers when one is given.
| Place | Kind | Date | Covers |
|---|---|---|---|
| Ontario | report | May 31, 2026 | calendar year 2025 |
| Ontario | report | May 31, 2026 | calendar year 2025 |
| 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 first annual report date is the same on both sides, May 31.
Penalties in Ontario 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 Ontario and Oregon
How the report file for Ontario compares with the one for Oregon.
| Aspect | Ontario | Oregon |
|---|---|---|
| Layout | Ontario Blue Box supply report (working layout) Working layout, sources reviewed 2026-11-04 | Oregon producer supply report by material category 2026-09-29 (built from CAA Oregon 2026 fee schedule) |
| Recipient | Resource Productivity and Recovery Authority (RPRA) | Circular Action Alliance (Oregon PRO) |
| How it is submitted | RPRA Registry (online). The customer signs in and enters or submits. | CAA producer portal. The customer signs in and submits. |
| File type | csv | csv |
| Encoding | utf-8 | utf-8 |
| Delimiter | , | , |
| Decimal separator | . | |
| Columns | 4 | 4 |
| Required columns | 4 of 4 | 4 of 4 |
| Weight unit | kg | lb |
| Period basis | calendar year | calendar year |
The two layouts share a file type and a delimiter, but each programme names its own columns and categories, so one file cannot be sent to both programmes. Each report is built from the same underlying measurements and exported separately.
Which to plan for first, Ontario or Oregon
Check the exemption thresholds before anything else. Ontario reaches smaller sellers than Oregon, so a seller that is exempt in Oregon may still have to register in Ontario.
Questions about comparing these two programmes
Is Ontario or Oregon stricter on packaging EPR?
Ontario exempts only producers below the lower revenue floor, CA$2,000,000 against $5,000,000 in Oregon. Both set the lowest weight exemption at 1 tonne. Both require producers to register. Both programmes set their first annual report for May 31.
Do I register in both Ontario and Oregon?
Ontario requires producers to register. Oregon requires producers to register.
How do the fees per kilogram compare in Ontario 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, Ontario or Oregon?
The first annual report date is the same on both sides, May 31.
How these figures are made
Sources
- rpra.ca: regulation retrieved
Original wording: Blue Box producers became fully accountable and financially responsible for collecting and recycling their materials when consumers discard them.
- rpra.ca: producers retrieved
Original wording: Unless otherwise stated, all information must be submitted through RPRA’s registry.
Original wording: if they supply Blue Box material (packaging, paper products or packaging-like products) comprised of paper, glass, metal or plastic
Original wording: Within 30 days of supplying obligated Blue Box materials in Ontario
Original wording: PROs operate in a competitive market, and producers can choose the PRO (or PROs) they want to work with.
Original wording: Producers have the choice of working with one or more producer responsibility organizations (PROs) registered with RPRA
Original wording: Any producer whose gross annual Ontario revenue from products and services is less than $2,000,000 is exempt from all producer requirements under the regulation.
Original wording: if the retailer who would be the producer is a marketplace seller, the marketplace facilitator is the obligated producer
Original wording: is exempt from all producer requirements under the regulation.
Original wording: Paper 9,000
Original wording: Rigid plastic 2,000
Original wording: Flexible plastic 2,000
Original wording: Glass 1,000
Original wording: Metal 1,000
Original wording: Beverage containers 1,000
Original wording: Any producer who meets the exemption must keep any records that demonstrate its gross annual Ontario revenue is less than $2,000,000
Original wording: the producer is required to register and report.
Original wording: newspaper must account for more than 70% of their total weight of Blue Box materials supplied to consumers in Ontario in a calendar year.
Original wording: Deadline: Supply data must be submitted by May 31 of each year.
Original wording: Deadline: Performance reporting is due May 31 of each year.
Original wording: Under the Blue Box Regulation, consumers are individuals who use a product and its packaging for personal, family or household purposes.
Original wording: beverage container, glass, flexible plastic, rigid plastic, metal, paper, and certified compostable products and packaging
Original wording: Management requirement = A × B
- 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
- Bank of Canada, FXAUSDCAD (annual average 2025) retrieved
- 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
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