Oregon vs Spain EPR: Rules Compared
Last verified
Oregon and Spain both run packaging EPR, but the rules differ. Both require producers to register. Spain asks for its first annual report earlier, on March 31 against May 31 in Oregon. Every figure below links to its primary source.
Oregon and Spain side by side
2 of 9 rows have a verified figure on each side of Oregon and Spain; 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 | Spain | Stricter |
|---|---|---|---|
| Registration duty | Required | Required | Same |
| Producer organisation | one producer responsibility organisation | more than one producer responsibility organisation | Not comparable |
| Lowest revenue exemption | $5,000,000 | none recorded; see thresholds | Not comparable |
| Lowest weight exemption | 1 tonne | none recorded; see thresholds | Not comparable |
| First annual report date | May 31 | March 31 | Spain |
| Published penalties | 1 published | 3 published | Not comparable |
| Report file | csv | csv | Not comparable |
| Paper fee, cheapest matched rate | 2.0 cents per pound | 0.117 EUR/kg | Not comparable |
| Plastic fee, cheapest matched rate | 12.0 cents per pound | 0.530 EUR/kg | Not comparable |
Both programmes require a producer to register, in Oregon and in Spain.
The earliest annual report date is May 31 in Oregon and March 31 in Spain, 61 days apart. Spain leaves less time to prepare, so its data has to be ready first.
Who runs the programme in Oregon and Spain
Who collects and who the producer files with, in Oregon and then Spain.
| Aspect | Oregon | Spain |
|---|---|---|
| Regime | Oregon Recycling Modernization Act, ORS 459A.860 to 459A.975 (SB 582 of 2021) | Royal Decree 1055/2022 on packaging and packaging waste, under Law 7/2022 on waste and contaminated soils |
| Regulator | Oregon Department of Environmental Quality (DEQ) | Ministry for the Ecological Transition (MITECO), Directorate-General for Environmental Quality and Assessment |
| Producers obligated | Yes | Yes |
| Registration | Required, Circular Action Alliance producer portal (PRO registration); DEQ holds no separate producer registry | Required, Packaging section of the Register of Product Producers (Registro de Productores de Productos) |
| Producer organisation | one producer responsibility organisation: Circular Action Alliance; membership required | more than one producer responsibility organisation: Ecoembes, Ecovidrio; membership required |
| Transfer of responsibility | Allowed | Allowed |
| Revenue counted as | organisation gross revenue, USD, fiscal year | not yet published |
| 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 | primary: manufacturer or brand owner, importer, first distributor; secondary: manufacturer or brand owner, importer, first distributor; service: manufacturer or brand owner, importer, first distributor; shipping: online marketplace seller, manufacturer or brand owner; tertiary: manufacturer or brand owner, importer, first distributor |
The two programmes are organised differently. Oregon uses one producer responsibility organisation; Spain uses more than 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 Oregon and Spain cover, side by side
Each row below is one published feature of the two programmes; a cell reads “not yet published” when Oregon or Spain has no verified entry for it in the dataset.
| Aspect | Oregon | Spain |
|---|---|---|
| Materials covered | packaging, printing and writing paper, food serviceware | all packaging materials, plastic, paper and cardboard, metal, glass, wood, other |
| Product classes covered | packaging, printing and writing paper, food serviceware | household packaging, commercial and industrial packaging, service packaging |
| 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 | domestic producers, producers established in other Member States or third countries via an authorised representative, e-commerce platforms acting as producer where no representative is appointed |
| Producer duty: primary packaging | manufacturer_brand_owner; licensee; importer | manufacturer_brand_owner; importer; first_distributor |
| Producer duty: secondary packaging | manufacturer_brand_owner; licensee; importer | manufacturer_brand_owner; importer; first_distributor |
| Producer duty: tertiary packaging | first_distributor | manufacturer_brand_owner; importer; first_distributor |
| Producer duty: shipping packaging | packer_shipper | online_marketplace_seller; manufacturer_brand_owner |
| Producer duty: service packaging | first_distributor | manufacturer_brand_owner; importer; first_distributor |
| Producer duty: other packaging | first_distributor | not yet published |
| Reporting categories | 60, covered material type by material class | not yet published |
| 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 | recycling rate, all packaging waste 65% by 2025-12-31; recycling rate, all packaging waste 70% by 2030-12-31 |
| 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. | not yet published |
| 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 |
Thresholds and exemptions in Oregon and Spain
Every verified threshold Oregon and Spain 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 |
| Spain | packaging weight | 10 tonnes per calendar year | reduced duty | packaging made available for the first time in the Member State |
| Spain | packaging weight | 15 tonnes per year | reduced duty | packaging placed on the market |
Oregon exemption: A small producer is exempt from PRO membership. Seven ways to qualify: nonprofit, public body, revenue under $5 million, under 1 metric ton, small beverage manufacturer, restaurant or food cart that is not a food-serviceware producer, single retail establishment with no online sales and no franchise or chain. It does not have to be applied for.
Oregon exemption: Product-specific exclusions from "covered product" listed in ORS 459A.863(6)(b)(A)-(R) and OAR 340-090-0840(2), such as Bottle Bill containers, bound books, drug packaging, farm items and architectural paint containers. It does not have to be applied for.
Oregon exemption: Material recycled through a non-Opportunity-to-Recycle collection, not separated at a commingled facility, and disposed to a responsible end market can be exempted if the producer demonstrates it to DEQ. Producers still report gross supply. It must be applied for.
Read the basis column first: the same amount can exempt a producer in one programme and only simplify its report in another.
Fees per kilogram for shared materials
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) | Spain (EUR per kg) | Spain in USD, approx. | Higher fee |
|---|---|---|---|---|
| paper and board | 2.0 cents per pound | 0.117 EUR/kg | not yet published | Not comparable |
| plastic | 12.0 cents per pound | 0.530 EUR/kg | not yet published | Not comparable |
| glass | 0.0 cents per pound | 0.03761 EUR/kg | not yet published | Not comparable |
| steel | 4.0 cents per pound | 0.197 EUR/kg | not yet published | Not comparable |
Scaling the cheapest published rate by weight shows what the gap between Oregon and Spain 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) | Spain fee (EUR) | Spain in USD, approx. | Spain minus Oregon (USD) |
|---|---|---|---|---|---|
| paper and board | 1 | $0.04 | €0.12 | not yet published | not yet published |
| paper and board | 10 | $0.44 | €1.17 | not yet published | not yet published |
| paper and board | 100 | $4.41 | €11.70 | not yet published | not yet published |
| paper and board | 1,000 | $44.09 | €117.00 | not yet published | not yet published |
| paper and board | 10,000 | $440.92 | €1,170.00 | not yet published | not yet published |
| paper and board | 100,000 | $4,409.25 | €11,700.00 | not yet published | not yet published |
| plastic | 1 | $0.26 | €0.53 | not yet published | not yet published |
| plastic | 10 | $2.65 | €5.30 | not yet published | not yet published |
| plastic | 100 | $26.46 | €53.00 | not yet published | not yet published |
| plastic | 1,000 | $264.55 | €530.00 | not yet published | not yet published |
| plastic | 10,000 | $2,645.55 | €5,300.00 | not yet published | not yet published |
| plastic | 100,000 | $26,455.47 | €53,000.00 | not yet published | not yet published |
| glass | 1 | $0.00 | €0.04 | not yet published | not yet published |
| glass | 10 | $0.00 | €0.38 | not yet published | not yet published |
| glass | 100 | $0.00 | €3.76 | not yet published | not yet published |
| glass | 1,000 | $0.00 | €37.61 | not yet published | not yet published |
| glass | 10,000 | $0.00 | €376.10 | not yet published | not yet published |
| glass | 100,000 | $0.00 | €3,761.00 | not yet published | not yet published |
| steel | 1 | $0.09 | €0.20 | not yet published | not yet published |
| steel | 10 | $0.88 | €1.97 | not yet published | not yet published |
| steel | 100 | $8.82 | €19.70 | not yet published | not yet published |
| steel | 1,000 | $88.18 | €197.00 | not yet published | not yet published |
| steel | 10,000 | $881.85 | €1,970.00 | not yet published | not yet published |
| steel | 100,000 | $8,818.49 | €19,700.00 | not yet published | not yet published |
The two schedules are in different currencies (USD and EUR) and the dataset holds no published exchange rate between them, so this page does not rank the fees. Compare them in your own currency before you decide.
Spain: the 2027 fee schedule of Ecoembes / Ecovidrio, 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.
Spain 2027: the category “Paper and cardboard, non-SUP” is published at 0.117 EUR/kg.
Spain 2027: the category “Plastic bags (UNE standard)” is published at 0.530 EUR/kg.
Spain 2027: the category “Glass (weight factor)” is published at 0.03761 EUR/kg.
Spain 2027: the category “Steel, beverage cans” is published at 0.197 EUR/kg.
Real packs usually land in a dearer category, so use the calculator for Oregon and Spain.
Deadlines in Oregon and Spain
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 |
| Spain | report | June 1 | the previous calendar year |
| Spain | other | August 12, 2026 | not yet published |
| Spain | report | March 31 | the previous calendar year |
The earliest annual report date is May 31 in Oregon and March 31 in Spain, 61 days apart. Spain leaves less time to prepare, so its data has to be ready first.
Penalties in Oregon and Spain
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.
Spain penalty for very serious infringement: €100,001 to €3,500,000 per infringement.
Spain penalty for serious infringement: €2,001 to €100,000 per infringement.
Spain penalty for minor infringement: up to €2,000 per infringement.
Report formats in Oregon and Spain
How the report file for Oregon compares with the one for Spain.
| Aspect | Oregon | Spain |
|---|---|---|
| Layout | Oregon producer supply report by material category 2026-09-29 (built from CAA Oregon 2026 fee schedule) | Spain packaging declaration (working layout) Working layout, sources reviewed 2026-11-04 |
| Recipient | Circular Action Alliance (Oregon PRO) | Ministerio para la Transición Ecológica: Registro de Productores de Producto, sección de envases |
| How it is submitted | CAA producer portal. The customer signs in and submits. | Registro de Productores de Productos (MITECO), packaging section; registry entry. 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 | lb | kg |
| 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 Spain
Plan around the earlier report date first. Spain asks for its first annual report on March 31, before Oregon, so its data has to be ready first.
Questions about comparing these two programmes
Is Oregon or Spain stricter on packaging EPR?
Both require producers to register. Spain asks for its first annual report earlier, on March 31 against May 31 in Oregon.
Do I register in both Oregon and Spain?
Oregon requires producers to register. Spain requires producers to register.
How do the fees per kilogram compare in Oregon and Spain?
The two schedules share material classes but the dataset holds no published exchange rate between USD and EUR, so the fees are shown in each currency without a ranking.
Which deadline comes first, Oregon or Spain?
The earliest annual report date is May 31 in Oregon and March 31 in Spain, 61 days apart. Spain leaves less time to prepare, so its data has to be ready first.
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
- boe.es: act (2022) (buscar) retrieved
Original wording: se crea la sección de envases en el Registro de Productores de Productos
Original wording: a través de la Dirección General de Calidad y Evaluación Ambiental
Original wording: se obliga a todos los envasadores a inscribirse y a remitir anualmente información
Original wording: se inscribirán en la sección de envases del Registro de Productores de Productos
Original wording: deberán designar a una persona física o jurídica en territorio español como representante autorizado
Original wording: un certificado de pertenencia a un sistema individual o colectivo de responsabilidad ampliada del productor
Original wording: menos de 15 toneladas de envases al año
Original wording: antes del 31 de marzo del año siguiente
- eur-lex.europa.eu: oj retrieved
Original wording: makes available for the first time on the territory of another Member State, directly to end users
Original wording: a quantity of packaging, including packaging of packaged products, of less than 10 tonnes during one calendar year
Original wording: of Annex IX to the competent authority responsible for the register, by 1 June for each full preceding calendar year.
Original wording: It shall apply from 12 August 2026.
Original wording: by 31 December 2030, a minimum of 70 % by weight of all packaging waste generated
- boe.es: act (2022) (buscar) retrieved
Original wording: Multa desde 100.001 euros hasta 3.500.000 euros
- 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
- ecoembesempresas.com: Ecoembes Precios2027 retrieved
Original wording: Precios 2027 Envases domésticos
Original wording: Envases no SUP 0, 117
Original wording: Bolsas UNE 0,530
Original wording: 0,03761 0,00533 + €/ud
Original wording: Latas de bebidas 0, 197
The free plan is enough to start. We estimate and prepare; you sign and submit.