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.
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.
| Measure | Oregon | Washington | Stricter |
|---|---|---|---|
| Registration duty | Required | Required | Same |
| Producer organisation | one producer responsibility organisation | one producer responsibility organisation | Not comparable |
| Lowest revenue exemption | $5,000,000 | $5,000,000 | Same |
| Lowest weight exemption | 1 tonne | 907.2 kg | Washington |
| First annual report date | May 31 | May 31 | Same |
| Published penalties | 1 published | 1 published | Not comparable |
| Report file | csv | csv | Not comparable |
| Paper fee, cheapest matched rate | 2.0 cents per pound | not yet published | Not comparable |
| Plastic fee, cheapest matched rate | 12.0 cents per pound | not yet published | Not 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.
| Aspect | Oregon | Washington |
|---|---|---|
| Regime | Oregon Recycling Modernization Act, ORS 459A.860 to 459A.975 (SB 582 of 2021) | Washington Recycling Reform Act, chapter 70A.208 RCW |
| Regulator | Oregon Department of Environmental Quality (DEQ) | Washington State Department of Ecology |
| Producers obligated | Yes | Yes |
| Registration | Required, Circular Action Alliance producer portal (PRO registration); DEQ holds no separate producer registry | Required, Producer registers with a PRO; the PRO registers with Ecology |
| Producer organisation | one producer responsibility organisation: Circular Action Alliance; membership required | one producer responsibility organisation: Circular Action Alliance; membership required |
| Transfer of responsibility | Allowed | not yet published |
| Revenue counted as | organisation gross revenue, USD, fiscal year | worldwide gross revenue, USD, prior fiscal 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 | primary: 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.
| Aspect | Oregon | Washington |
|---|---|---|
| Materials covered | packaging, printing and writing paper, food serviceware | packaging, paper products |
| Product classes covered | packaging, printing and writing paper, food serviceware | packaging, paper |
| 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 | exempt materials |
| Sales channels addressed | physical retail, remote sale, other distribution | physical retail, remote sale, other distribution |
| Producer duty: primary packaging | manufacturer_brand_owner; licensee; importer | manufacturer; licensee; brand_owner; importer |
| Producer duty: secondary packaging | manufacturer_brand_owner; licensee; importer | not yet published |
| Producer duty: tertiary packaging | first_distributor | not yet published |
| Producer duty: shipping packaging | packer_shipper | not yet published |
| Producer duty: service packaging | first_distributor | not yet published |
| 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 | 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. | A de minimis producer is under one ton, or under the global revenue limit, or an agricultural employer within limits. |
| 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. | Registered 501(c)(3) and 501(c)(4) organizations are excluded from the producer definition. |
| 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 Washington
Every verified threshold Oregon and Washington 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 |
| Washington | packaging tonnage | 1 short ton | exempt below | covered materials introduced, most recent fiscal year |
| Washington | revenue | $5,000,000 | exempt below | global 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.
| 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 |
| Washington | other | March 1, 2026 | not yet published |
| Washington | report | May 31, 2026 | not yet published |
| Washington | registration | July 1, 2026 | not yet published |
| Washington | other | October 1, 2028 | not yet published |
| Washington | other | March 1, 2029 | not yet published |
| Washington | other | January 1, 2030 | not yet published |
| Washington | payment | February 15, 2031 | not yet published |
| Washington | payment | February 15, 2032 | not 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.
| Aspect | Oregon | Washington |
|---|---|---|
| Layout | Oregon 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) |
| Recipient | Circular Action Alliance (Oregon PRO) | Circular Action Alliance (Washington PRO) |
| How it is submitted | CAA producer portal. The customer signs in and 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 | lb | 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, 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
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
- 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)
- 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.
- 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.
- 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
The free plan is enough to start. We estimate and prepare; you sign and submit.