Oregon vs Québec EPR: Rules Compared
Last verified
Oregon and Québec both run packaging EPR, but the rules differ. Québec exempts only producers below the lower revenue floor, CA$1,300,000 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.
Oregon and Québec side by side
6 of 9 rows have a verified figure on each side of Oregon and Québec; 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 | Oregon | Québec | Stricter |
|---|---|---|---|
| Registration duty | Required | Required | Same |
| Producer organisation | one producer responsibility organisation | one producer responsibility organisation | Not comparable |
| Lowest revenue exemption | $5,000,000 | CA$1,300,000 | Québec |
| Lowest weight exemption | 1 tonne | 1 tonne | Same |
| First annual report date | May 31 | May 31 | Same |
| Published penalties | 1 published | not yet published | Not comparable |
| Report file | csv | csv | Not comparable |
| Paper fee, cheapest matched rate | 2.0 cents per pound | 806.84 CAD/tonne | Québec |
| Plastic fee, cheapest matched rate | 12.0 cents per pound | 1,882.29 CAD/tonne | Québec |
The lowest revenue exemption is $5,000,000 in Oregon and CA$1,300,000 in Québec ($930,033 at the Bank of Canada 2025 annual average rate). Québec therefore reaches smaller sellers: a business with revenue between the two lines is exempt in Oregon but still in scope in Québec.
The lowest weight exemption is the same on both sides: 1 tonne of packaging.
Both programmes require a producer to register, in Oregon and in Québec.
The first annual report date is the same on both sides, May 31.
Across 4 shared material classes, Québec publishes the higher cheapest per-kilogram fee in 4, and Oregon in 0. A higher fee is not the same as a stricter rule; it is simply a larger published number per kilogram.
Who runs the programme in Oregon and Québec
Who collects and who the producer files with, in Oregon and then Québec.
| Aspect | Oregon | Québec |
|---|---|---|
| Regime | Oregon Recycling Modernization Act, ORS 459A.860 to 459A.975 (SB 582 of 2021) | Regulation respecting a system of selective collection of certain residual materials (Q-2, r. 46.01) |
| Regulator | Oregon Department of Environmental Quality (DEQ) | not yet published |
| Producers obligated | Yes | Yes |
| Registration | Required, Circular Action Alliance producer portal (PRO registration); DEQ holds no separate producer registry | Required, ÉEQ declaration portal |
| Producer organisation | one producer responsibility organisation: Circular Action Alliance; membership required | one producer responsibility organisation: Éco Entreprises Québec (ÉEQ); membership required |
| Transfer of responsibility | Allowed | not yet published |
| Revenue counted as | organisation gross revenue, USD, fiscal year | gross revenue inside the jurisdiction, CAD, year |
| Who counts as the producer | 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 | other: brand owner, first distributor, online marketplace, seller; primary: brand owner, first distributor, online marketplace, seller; secondary: brand owner, first distributor, online marketplace, seller; service: brand owner, first distributor, online marketplace, seller; shipping: brand owner, first distributor, online marketplace, seller; tertiary: brand owner, first distributor, online marketplace, seller |
Both programmes organise producer responsibility the same way: one producer responsibility organisation. The practical differences between Oregon and Québec therefore sit in thresholds, fees, dates and report formats rather than in whom a producer deals with.
What Oregon and Québec cover, side by side
Each row below is one published feature of the two programmes; a cell reads “not yet published” when Oregon or Québec has no verified entry for it in the dataset.
| Aspect | Oregon | Québec |
|---|---|---|
| Materials covered | packaging, printing and writing paper, food serviceware | paper, plastic, metal, glass, printed paper, packaging |
| Product classes covered | packaging, printing and writing paper, food serviceware | containers, packaging, printed matter |
| Excluded from scope | 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 | not yet published |
| Sales channels addressed | physical retail, remote sale, other distribution | retail, online, distance sale |
| Producer duty: primary packaging | manufacturer_brand_owner; licensee; importer | brand_owner; first_distributor; marketplace; seller |
| Producer duty: secondary packaging | manufacturer_brand_owner; licensee; importer | brand_owner; first_distributor; marketplace; seller |
| Producer duty: tertiary packaging | first_distributor | brand_owner; first_distributor; marketplace; seller |
| Producer duty: shipping packaging | packer_shipper | brand_owner; first_distributor; marketplace; seller |
| Producer duty: service packaging | first_distributor | brand_owner; first_distributor; marketplace; seller |
| Producer duty: other packaging | first_distributor | brand_owner; first_distributor; marketplace; seller |
| Reporting categories | 60, covered material type by material class | 21, material category |
| Published targets | 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 | not yet published |
| Exemption 1 | 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. | Under 1 tonne AND sales under 1.3 million: no report |
| Exemption 2 | 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. | not yet published |
| Exemption 3 | 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) | not yet published |
| Labelling | not yet published | Required: Charter of the French Language: s. 51: every inscription on the product, its container or wrapping, and on documents supplied with it (directions for use, warranty certificates) must be in French; a translation may accompany it but never be more prominent than the French.; s. 51.1 and Regulation C-11, r. 9, s. 7.1 (from June 1, 2025): a registered trademark with no French version on the Canadian register may stay in another language, but any generic or descriptive words in it must appear in French on the product or on a medium permanently attached to it. |
Thresholds and exemptions in Oregon and Québec
Every verified threshold Oregon and Québec publish, as each states it.
| Place | Measure | Amount | Effect | Basis as published |
|---|---|---|---|---|
| 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 |
| Québec | packaging tonnage | 1 tonne | exempt below | targeted materials |
| Québec | packaging tonnage | 1 tonne | exempt below | targeted materials placed on the market |
| Québec | revenue | CA$1,300,000 | exempt below | annual sales (the fee schedule page says 1M or less, 1.3M as of 2024; the step-by-step reporting page says less than 1.3M) |
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.
Québec exemption: Under 1 tonne AND sales under 1.3 million: no report It does not have to 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 $5,000,000 in Oregon and CA$1,300,000 in Québec ($930,033 at the Bank of Canada 2025 annual average rate). Québec therefore reaches smaller sellers: a business with revenue between the two lines is exempt in Oregon but still in scope in Québec.
The lowest weight exemption is the same on both sides: 1 tonne of packaging.
Fees per kilogram for shared materials
4 material classes have a published rate on both sides; each row shows the cheapest rate that fits the class.
| Material class | Oregon (USD per kg) | Québec (CAD per kg) | Québec in USD, approx. | Higher fee |
|---|---|---|---|---|
| paper and board | 2.0 cents per pound | 806.84 CAD/tonne | $0.5772 | Québec |
| plastic | 12.0 cents per pound | 1,882.29 CAD/tonne | $1.3466 | Québec |
| glass | 0.0 cents per pound | 654.24 CAD/tonne | $0.468 | Québec |
| steel | 4.0 cents per pound | 703.17 CAD/tonne | $0.5031 | Québec |
Scaling the cheapest published rate by weight shows what the gap between Oregon and Québec amounts to for a given tonnage of one material. The amounts are the rate times the weight, nothing added.
| Material class | Kilograms | Oregon fee (USD) | Québec fee (CAD) | Québec in USD, approx. | Québec minus Oregon (USD) |
|---|---|---|---|---|---|
| paper and board | 1 | $0.04 | CA$0.81 | $0.58 | +$0.53 |
| paper and board | 10 | $0.44 | CA$8.07 | $5.77 | +$5.33 |
| paper and board | 100 | $4.41 | CA$80.68 | $57.72 | +$53.31 |
| paper and board | 1,000 | $44.09 | CA$806.84 | $577.22 | +$533.13 |
| paper and board | 10,000 | $440.92 | CA$8,068.40 | $5,772.21 | +$5,331.29 |
| paper and board | 100,000 | $4,409.25 | CA$80,684.00 | $57,722.13 | +$53,312.89 |
| plastic | 1 | $0.26 | CA$1.88 | $1.35 | +$1.08 |
| plastic | 10 | $2.65 | CA$18.82 | $13.47 | +$10.82 |
| plastic | 100 | $26.46 | CA$188.23 | $134.66 | +$108.21 |
| plastic | 1,000 | $264.55 | CA$1,882.29 | $1,346.61 | +$1,082.05 |
| plastic | 10,000 | $2,645.55 | CA$18,822.90 | $13,466.09 | +$10,820.54 |
| plastic | 100,000 | $26,455.47 | CA$188,229.00 | $134,660.90 | +$108,205.42 |
| glass | 1 | $0.00 | CA$0.65 | $0.47 | +$0.47 |
| glass | 10 | $0.00 | CA$6.54 | $4.68 | +$4.68 |
| glass | 100 | $0.00 | CA$65.42 | $46.80 | +$46.80 |
| glass | 1,000 | $0.00 | CA$654.24 | $468.05 | +$468.05 |
| glass | 10,000 | $0.00 | CA$6,542.40 | $4,680.50 | +$4,680.50 |
| glass | 100,000 | $0.00 | CA$65,424.00 | $46,804.98 | +$46,804.98 |
| steel | 1 | $0.09 | CA$0.70 | $0.50 | +$0.41 |
| steel | 10 | $0.88 | CA$7.03 | $5.03 | +$4.15 |
| steel | 100 | $8.82 | CA$70.32 | $50.31 | +$41.49 |
| steel | 1,000 | $88.18 | CA$703.17 | $503.05 | +$414.87 |
| steel | 10,000 | $881.85 | CA$7,031.70 | $5,030.55 | +$4,148.70 |
| steel | 100,000 | $8,818.49 | CA$70,317.00 | $50,305.48 | +$41,486.99 |
Converted from CAD to USD at the Bank of Canada annual average for 2025. A converted figure is approximate and moves with the year of the rate; the published amount is the one in the programme’s own currency.
Québec: the 2027 fee schedule of Éco Entreprises Québec (ÉEQ), effective January 1, 2027, is the source of the per-kilogram rates used on this page.
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.
Oregon 2027: the category “Steel Containers” is published at 4.0 cents per pound.
Québec 2027: the category “Boxboard, other paper packaging and alternative fibres” is published at 806.84 CAD/tonne.
Québec 2027: the category “HDPE and LDPE films or shopping bags” is published at 1,882.29 CAD/tonne.
Québec 2027: the category “Clear glass” is published at 654.24 CAD/tonne.
Québec 2027: the category “Steel” is published at 703.17 CAD/tonne.
Real packs usually land in a dearer category, so use the calculator for Oregon and Québec.
Deadlines in Oregon and Québec
Each verified date, with the period it covers when one is given.
| Place | Kind | Date | Covers |
|---|---|---|---|
| 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 |
| Québec | report | May 31, 2026 | 2026 report (supply data used for the 2027 producer financial participation, PFP 2027) |
| Québec | other | June 30, 2026 | 2026 report |
| Québec | payment | January 31, 2027 | PFP 2027 (contribution based on the 2026 report), installment 1 of 4 |
| Québec | payment | April 30, 2027 | PFP 2027 (contribution based on the 2026 report), installment 2 of 4 |
| Québec | payment | July 31, 2027 | PFP 2027 (contribution based on the 2026 report), installment 3 of 4 |
| Québec | payment | October 31, 2027 | PFP 2027 (contribution based on the 2026 report), installment 4 of 4 |
| Québec | other | May 31, 2028 | 2026 report |
The first annual report date is the same on both sides, May 31.
Penalties in Oregon and Québec
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 Oregon and Québec
How the report file for Oregon compares with the one for Québec.
| Aspect | Oregon | Québec |
|---|---|---|
| Layout | Oregon producer supply report by material category 2026-09-29 (built from CAA Oregon 2026 fee schedule) | ÉEQ annual declaration Fee-year categories, reviewed 2026-09-29 |
| Recipient | Circular Action Alliance (Oregon PRO) | Éco Entreprises Québec |
| How it is submitted | CAA producer portal. The customer signs in and submits. | declaration.eeq.ca |
| 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 | lb | tonne |
| 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, Oregon or Québec
Check the exemption thresholds before anything else. Québec reaches smaller sellers than Oregon, so a seller that is exempt in Oregon may still have to register in Québec.
Questions about comparing these two programmes
Is Oregon or Québec stricter on packaging EPR?
Québec exempts only producers below the lower revenue floor, CA$1,300,000 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. Québec publishes the higher per-kilogram fee in 4 of 4 shared material classes.
Do I register in both Oregon and Québec?
Oregon requires producers to register. Québec requires producers to register.
How do the fees per kilogram compare in Oregon and Québec?
Across 4 shared material classes, Québec publishes the higher cheapest per-kilogram fee in 4, and Oregon in 0. A higher fee is not the same as a stricter rule; it is simply a larger published number per kilogram.
Which deadline comes first, Oregon or Québec?
The first annual report date is the same on both sides, May 31.
How these figures are made
Sources
- 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
- eeq.ca retrieved
Original wording: Regulation respecting a system of selective collection of certain residual materials
- eeq.ca: preparing and submitting your report step by step retrieved
Original wording: You run an online store, with or without a place of business in Quebec.
Original wording: annual sales of less than $1.3 million.
Original wording: your business generates less than one metric ton of targeted materials and has annual sales of less than $1.3 million.
- legisquebec.gouv.qc.ca: Q 2, r. 46.01 retrieved
Original wording: incombent à la personne domiciliée ou qui a un établissement au Québec qui y agit à titre de premier fournisseur, à l’exclusion du fabricant
- eeq.ca: fee schedule to help with your report retrieved
Original wording: Are a retailer with a single outlet with a floor space of less than 929 m²
Original wording: Newspapers
Original wording: 2027 Producer financial participation (PFP)
Original wording: Boxboard and other paper packaging Alternative fibers $806.84
Original wording: HDPE and LDPE plastic films or shopping bags $1,882.29
Original wording: Clear glass $654.24
Original wording: Containers, including aerosol containers $703.17
- eeq.ca: important dates for your report retrieved
Original wording: Reporting deadline: May 31, 2026
Original wording: Deadline to submit a Bonus application: June 30, 2026
- eeq.ca: les dates a retenir pour votre declaration retrieved
Original wording: Date limite pour payer chacun des quatre versements de PFP 2027 : 31 janvier 2027, 30 avril 2027, 31 juillet 2027, 31 octobre 2027
Original wording: Date limite pour formuler une demande de modifications : 31 mai 2028
- legisquebec.gouv.qc.ca: C 11 retrieved
Original wording: if a generic term or a description of the product is included in the trademark, it must appear in French on the product
- 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
Original wording: Steel Containers USCL 0.09 0.00 -0.05 0.04
The free plan is enough to start. We estimate and prepare; you sign and submit.