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Oregon vs Washington EPR: Rules Compared

Last verified

Oregon and Washington both run packaging EPR, but the rules differ. Both set the lowest revenue exemption at $5,000,000. Washington has the lower weight floor, 907.2 kg against 1 tonne in Oregon. Both require producers to register. Both programmes set their first annual report for May 31.

Paired bars comparing how many verified thresholds, deadlines and penalties Oregon and Washington publish, and how many columns their report layouts hold.Oregon / Washington (published items): Thresholds: Oregon 4, Washington 2; Deadlines: Oregon 4, Washington 8; Penalties: Oregon 1, Washington 1; Report columns: Oregon 4, Washington 4OregonWashingtonpublished items02468Thresholds42Deadlines48Penalties11Report columns44
Source: Oregon and Washington primary sources, retrieved 2026-11-05

Oregon and Washington side by side

4 of 9 rows have a verified figure on each side of Oregon and Washington; 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.

Oregon and Washington: the measures both programmes publish
MeasureOregonWashingtonStricter
Registration dutyRequiredRequiredSame
Producer organisationone producer responsibility organisationone producer responsibility organisationNot comparable
Lowest revenue exemption$5,000,000$5,000,000Same
Lowest weight exemption1 tonne907.2 kgWashington
First annual report dateMay 31May 31Same
Published penalties1 published1 publishedNot comparable
Report filecsvcsvNot comparable
Paper fee, cheapest matched rate2.0 cents per poundnot yet publishedNot comparable
Plastic fee, cheapest matched rate12.0 cents per poundnot yet publishedNot comparable

The lowest revenue exemption is the same on both sides: $5,000,000. A seller just under that line is out of scope in Oregon and in Washington alike.

The lowest weight exemption is 1 tonne of packaging in Oregon and 907.2 kg in Washington, about 1.1 times as much in Oregon as in Washington. A seller whose packaging falls between the two lines is exempt in Oregon but counted in Washington.

Both programmes require a producer to register, in Oregon and in Washington.

The first annual report date is the same on both sides, May 31.

Who runs the programme in Oregon and Washington

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

Oregon and Washington: how each programme is set up
AspectOregonWashington
RegimeOregon Recycling Modernization Act, ORS 459A.860 to 459A.975 (SB 582 of 2021)Washington Recycling Reform Act, chapter 70A.208 RCW
RegulatorOregon Department of Environmental Quality (DEQ)Washington State Department of Ecology
Producers obligatedYesYes
RegistrationRequired, Circular Action Alliance producer portal (PRO registration); DEQ holds no separate producer registryRequired, Producer registers with a PRO; the PRO registers with Ecology
Producer organisationone producer responsibility organisation: Circular Action Alliance; membership requiredone producer responsibility organisation: Circular Action Alliance; membership required
Transfer of responsibilityAllowednot yet published
Revenue counted asorganisation gross revenue, USD, fiscal yearworldwide gross revenue, USD, prior fiscal year
Who counts as the producerother: 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 distributorprimary: manufacturer, brand licensee, brand owner, importer

Both programmes organise producer responsibility the same way: one producer responsibility organisation. The practical differences between Oregon and Washington therefore sit in thresholds, fees, dates and report formats rather than in whom a producer deals with.

What Oregon and Washington cover, side by side

Each row below is one published feature of the two programmes; a cell reads “not yet published” when Oregon or Washington has no verified entry for it in the dataset.

Scope, producer duties, categories, labelling and targets, Oregon and Washington
AspectOregonWashington
Materials coveredpackaging, printing and writing paper, food servicewarepackaging, paper products
Product classes coveredpackaging, printing and writing paper, food servicewarepackaging, paper
Excluded from scopebeverage 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 claimexempt materials
Sales channels addressedphysical retail, remote sale, other distributionphysical retail, remote sale, other distribution
Producer duty: primary packagingmanufacturer_brand_owner; licensee; importermanufacturer; licensee; brand_owner; importer
Producer duty: secondary packagingmanufacturer_brand_owner; licensee; importernot yet published
Producer duty: tertiary packagingfirst_distributornot yet published
Producer duty: shipping packagingpacker_shippernot yet published
Producer duty: service packagingfirst_distributornot yet published
Producer duty: other packagingfirst_distributornot yet published
Reporting categories60, covered material type by material classnot yet published
Published targetsstatewide_plastic_recycling_rate 25 by 2028-12-31; statewide_plastic_recycling_rate 50 by 2040-12-31; statewide_plastic_recycling_rate 70 by 2050-12-31not yet published
Exemption 1A 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.A de minimis producer is under one ton, or under the global revenue limit, or an agricultural employer within limits.
Exemption 2Product-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.Registered 501(c)(3) and 501(c)(4) organizations are excluded from the producer definition.
Exemption 3Material 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 Washington

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

Verified thresholds in Oregon and Washington
PlaceMeasureAmountEffectBasis as published
Oregonrevenue$5,000,000exempt belowgross revenue, most recent fiscal year
Oregonpackaging tonnage1 metric tonexempt belowcovered products sold in or into Oregon, most recent calendar year
Oregonpackaging tonnage5 metric tonsexempt belowcovered products, including secondary and tertiary packaging for beverage containers, most recent calendar year
Oregonrevenue$10,000,000flat-fee bandgross revenue, most recent fiscal year, or under 5 metric tons sold in or into Oregon
Washingtonpackaging tonnage1 short tonexempt belowcovered materials introduced, most recent fiscal year
Washingtonrevenue$5,000,000exempt belowglobal gross revenue, prior fiscal year

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.

Washington exemption: A de minimis producer is under one ton, or under the global revenue limit, or an agricultural employer within limits. It does not have to be applied for.

Washington exemption: Registered 501(c)(3) and 501(c)(4) organizations are excluded from the producer definition. 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 the same on both sides: $5,000,000. A seller just under that line is out of scope in Oregon and in Washington alike.

The lowest weight exemption is 1 tonne of packaging in Oregon and 907.2 kg in Washington, about 1.1 times as much in Oregon as in Washington. A seller whose packaging falls between the two lines is exempt in Oregon but counted in Washington.

Fees per kilogram for shared materials

Oregon publishes per-kilogram rates in the dataset; Washington does not. The rows therefore show Oregon only. Until both sides publish per-kilogram rates for the same material class, a fee comparison between Oregon and Washington 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 Oregon and Washington

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

Verified deadlines in Oregon and Washington
PlaceKindDateCovers
OregonreportMay 31, 2026calendar year 2025
OregonotherJuly 1, 2025not yet published
OregonotherJanuary 1, 2027not yet published
OregonreportDecember 31, 2026not yet published
WashingtonotherMarch 1, 2026not yet published
WashingtonreportMay 31, 2026not yet published
WashingtonregistrationJuly 1, 2026not yet published
WashingtonotherOctober 1, 2028not yet published
WashingtonotherMarch 1, 2029not yet published
WashingtonotherJanuary 1, 2030not yet published
WashingtonpaymentFebruary 15, 2031not yet published
WashingtonpaymentFebruary 15, 2032not yet published

The first annual report date is the same on both sides, May 31.

Penalties in Oregon and Washington

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.

Washington penalty for producer violating chapter 70A.208 RCW: up to $1,000 per day.

Report formats in Oregon and Washington

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

Report file layouts for Oregon and Washington
AspectOregonWashington
LayoutOregon producer supply report by material category 2026-09-29 (built from CAA Oregon 2026 fee schedule)Washington interim producer supply report by material class 2026-09-29 (interim, built from CAA guidance)
RecipientCircular Action Alliance (Oregon PRO)Circular Action Alliance (Washington PRO)
How it is submittedCAA producer portal. The customer signs in and submits.CAA producer portal. The customer signs in and submits.
File typecsvcsv
Encodingutf-8utf-8
Delimiter,,
Decimal separator.
Columns44
Required columns4 of 44 of 4
Weight unitlblb
Period basiscalendar yearcalendar 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 Washington

Check the exemption thresholds before anything else. Washington reaches smaller sellers than Oregon, so a seller that is exempt in Oregon may still have to register in Washington.

Questions about comparing these two programmes

Is Oregon or Washington stricter on packaging EPR?

Both set the lowest revenue exemption at $5,000,000. Washington has the lower weight floor, 907.2 kg against 1 tonne in Oregon. Both require producers to register. Both programmes set their first annual report for May 31.

Do I register in both Oregon and Washington?

Oregon requires producers to register. Washington requires producers to register.

How do the fees per kilogram compare in Oregon and Washington?

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, Oregon or Washington?

The first annual report date is the same on both sides, May 31.

How these figures are made

Our reviewers.

Sources

  1. 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.
  2. 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
  3. 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.
  4. oregon.public.law: ors 459A.866 retrieved
    Original wording: the producer of the packaging is the person that manufactures the packaged item
  5. 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
  6. 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
  7. 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.
  8. circularactionalliance.org: producer reporting retrieved
    Original wording: Oregon's 2026 Report is due May 31, 2026, based on the 2025 Data Year.
  9. 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.
  10. oregon.public.law: ors 459A.926 retrieved
    Original wording: At least 25 percent by calendar year 2028 and in each subsequent year
  11. circularactionalliance.org: washington retrieved
    Original wording: required in the Recycling Reform Act
    Original wording: By January 1, 2026 Washington Department of Ecology must establish and appoint the initial membership of the advisory council.
    Original wording: July 1, 2026 Washington regulatory deadline for Producers to register with a PRO.
    Original wording: By March 1, 2026 A PRO must register with Washington Department of Ecology on behalf of its producers.
    Original wording: By May 31, 2026 Reporting (Interim State Addendum Signed & Simplified Reporting)
  12. app.leg.wa.gov: default retrieved
    Original wording: After July 1, 2026, be a member of a producer responsibility organization registered in this state
    Original wording: Has a global gross revenue, not including on-premises alcohol sales, for the prior fiscal year of
    Original wording: the producer is the person that manufactures the item
    Original wording: In their most recent fiscal year introduced less than one ton of covered materials
    Original wording: Until January 1, 2031, less than $5,000,000
    Original wording: "De minimis producer" means a producer that
    Original wording: Registered 501(c)(3) charitable organizations and 501(c)(4) social welfare organizations
    Original wording: By October 1, 2028, and every five years thereafter, submit a plan that meets the requirements of this chapter
    Original wording: Beginning March 1, 2029, a producer that is not a member in good standing with a registered producer responsibility organization
    Original wording: By January 1, 2030, or within six months of plan approval, whichever is later, implement the plan approved by the department
    Original wording: No less than 75 percent of the net costs by February 15, 2031
    Original wording: No less than 90 percent of the net costs by February 15, 2032, and each year thereafter
    Original wording: civil penalty of up to $1,000 per violation per day on any producer who violates this chapter
    Original wording: "Covered material" means packaging and paper products introduced into the state.
  13. ecology.wa.gov: producer responsibility organization retrieved
    Original wording: The Circular Action Alliance is the PRO representing producers in Washington. We encourage all potentially obligated producers to register with CAA.
  14. 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
Model both: Oregon and WashingtonCompare another pair

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