Oregon vs Yukon EPR: Rules Compared
Last verified
Oregon and Yukon both run packaging EPR, but the rules differ. Yukon exempts only producers below the lower revenue floor, CA$1,000,000 against $5,000,000 in Oregon. Both set the lowest weight exemption at 1 tonne. Both programmes set their first annual report for May 31. Yukon publishes the higher per-kilogram fee in 4 of 4 shared material classes.
Oregon and Yukon side by side
5 of 9 rows have a verified figure on each side of Oregon and Yukon; 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 | Yukon | Stricter |
|---|---|---|---|
| Registration duty | Required | not yet published | Not comparable |
| Producer organisation | one producer responsibility organisation | one producer responsibility organisation | Not comparable |
| Lowest revenue exemption | $5,000,000 | CA$1,000,000 | Yukon |
| 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 | 136 cents per kilogram | Yukon |
| Plastic fee, cheapest matched rate | 12.0 cents per pound | 588 cents per kilogram | Yukon |
The lowest revenue exemption is $5,000,000 in Oregon and CA$1,000,000 in Yukon ($715,410 at the Bank of Canada 2025 annual average rate). Yukon therefore reaches smaller sellers: a business with revenue between the two lines is exempt in Oregon but still in scope in Yukon.
The lowest weight exemption is the same on both sides: 1 tonne of packaging.
The first annual report date is the same on both sides, May 31.
Across 4 shared material classes, Yukon 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 Yukon
Who collects and who the producer files with, in Oregon and then Yukon.
| Aspect | Oregon | Yukon |
|---|---|---|
| Regime | Oregon Recycling Modernization Act, ORS 459A.860 to 459A.975 (SB 582 of 2021) | Extended Producer Responsibility Regulation, OIC 2024/19 (effective 2024-01-25; launched 2025-11-01) |
| Regulator | Oregon Department of Environmental Quality (DEQ) | Government of Yukon, Ministry of the Environment |
| Producers obligated | Yes | Yes |
| Registration | Required, Circular Action Alliance producer portal (PRO registration); DEQ holds no separate producer registry | not yet published |
| Producer organisation | one producer responsibility organisation: Circular Action Alliance; membership required | one producer responsibility organisation: Circular Materials; membership required |
| Transfer of responsibility | Allowed | not yet published |
| Revenue counted as | organisation gross revenue, USD, fiscal year | gross revenue inside the jurisdiction, CAD, completed 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, importer, seller, online marketplace; primary: brand owner, importer, seller, online marketplace; secondary: brand owner, importer, seller, online marketplace; service: seller, online marketplace; shipping: brand owner, importer, seller, online marketplace; tertiary: brand owner, importer, seller, online marketplace |
Both programmes organise producer responsibility the same way: one producer responsibility organisation. The practical differences between Oregon and Yukon therefore sit in thresholds, fees, dates and report formats rather than in whom a producer deals with.
What Oregon and Yukon cover, side by side
Each row below is one published feature of the two programmes; a cell reads “not yet published” when Oregon or Yukon has no verified entry for it in the dataset.
| Aspect | Oregon | Yukon |
|---|---|---|
| Materials covered | packaging, printing and writing paper, food serviceware | not yet published |
| Product classes covered | packaging, printing and writing paper, food serviceware | not yet published |
| 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 | not yet published |
| Producer duty: primary packaging | manufacturer_brand_owner; licensee; importer | brand_owner; importer; seller; marketplace |
| Producer duty: secondary packaging | manufacturer_brand_owner; licensee; importer | brand_owner; importer; seller; marketplace |
| Producer duty: tertiary packaging | first_distributor | brand_owner; importer; seller; marketplace |
| Producer duty: shipping packaging | packer_shipper | brand_owner; importer; seller; marketplace |
| Producer duty: service packaging | first_distributor | seller; marketplace |
| Producer duty: other packaging | first_distributor | brand_owner; importer; seller; marketplace |
| Reporting categories | 60, covered material type by material class | 36, 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. | Charity, under CAD 1,000,000 Yukon revenue or under one tonne |
| 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 Yukon
Every verified threshold Oregon and Yukon 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 |
| Yukon | revenue | CA$1,000,000 | exempt below | revenue in Yukon |
| Yukon | packaging tonnage | 1 tonne | exempt below | supply |
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.
Yukon exemption: Charity, under CAD 1,000,000 Yukon revenue or under one tonne 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$1,000,000 in Yukon ($715,410 at the Bank of Canada 2025 annual average rate). Yukon therefore reaches smaller sellers: a business with revenue between the two lines is exempt in Oregon but still in scope in Yukon.
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) | Yukon (CAD per kg) | Yukon in USD, approx. | Higher fee |
|---|---|---|---|---|
| paper and board | 2.0 cents per pound | 136 cents per kilogram | $0.973 | Yukon |
| plastic | 12.0 cents per pound | 588 cents per kilogram | $4.2066 | Yukon |
| glass | 0.0 cents per pound | 122 cents per kilogram | $0.8728 | Yukon |
| steel | 4.0 cents per pound | 211 cents per kilogram | $1.5095 | Yukon |
Scaling the cheapest published rate by weight shows what the gap between Oregon and Yukon 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) | Yukon fee (CAD) | Yukon in USD, approx. | Yukon minus Oregon (USD) |
|---|---|---|---|---|---|
| paper and board | 1 | $0.04 | CA$1.36 | $0.97 | +$0.93 |
| paper and board | 10 | $0.44 | CA$13.60 | $9.73 | +$9.29 |
| paper and board | 100 | $4.41 | CA$136.00 | $97.30 | +$92.89 |
| paper and board | 1,000 | $44.09 | CA$1,360.00 | $972.96 | +$928.87 |
| paper and board | 10,000 | $440.92 | CA$13,600.00 | $9,729.58 | +$9,288.65 |
| paper and board | 100,000 | $4,409.25 | CA$136,000.00 | $97,295.75 | +$92,886.51 |
| plastic | 1 | $0.26 | CA$5.88 | $4.21 | +$3.94 |
| plastic | 10 | $2.65 | CA$58.80 | $42.07 | +$39.42 |
| plastic | 100 | $26.46 | CA$588.00 | $420.66 | +$394.21 |
| plastic | 1,000 | $264.55 | CA$5,880.00 | $4,206.61 | +$3,942.06 |
| plastic | 10,000 | $2,645.55 | CA$58,800.00 | $42,066.10 | +$39,420.56 |
| plastic | 100,000 | $26,455.47 | CA$588,000.00 | $420,661.04 | +$394,205.57 |
| glass | 1 | $0.00 | CA$1.22 | $0.87 | +$0.87 |
| glass | 10 | $0.00 | CA$12.20 | $8.73 | +$8.73 |
| glass | 100 | $0.00 | CA$122.00 | $87.28 | +$87.28 |
| glass | 1,000 | $0.00 | CA$1,220.00 | $872.80 | +$872.80 |
| glass | 10,000 | $0.00 | CA$12,200.00 | $8,728.00 | +$8,728.00 |
| glass | 100,000 | $0.00 | CA$122,000.00 | $87,280.01 | +$87,280.01 |
| steel | 1 | $0.09 | CA$2.11 | $1.51 | +$1.42 |
| steel | 10 | $0.88 | CA$21.10 | $15.10 | +$14.21 |
| steel | 100 | $8.82 | CA$211.00 | $150.95 | +$142.13 |
| steel | 1,000 | $88.18 | CA$2,110.00 | $1,509.51 | +$1,421.33 |
| steel | 10,000 | $881.85 | CA$21,100.00 | $15,095.15 | +$14,213.30 |
| steel | 100,000 | $8,818.49 | CA$211,000.00 | $150,951.50 | +$142,133.00 |
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.
Yukon: the 2027 fee schedule of Circular Materials Yukon, 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.
Yukon 2027: the category “Boxboard and Other Paper Packaging” is published at 136 cents per kilogram.
Yukon 2027: the category “LDPE/HDPE Film” is published at 588 cents per kilogram.
Yukon 2027: the category “Clear Glass” is published at 122 cents per kilogram.
Yukon 2027: the category “Other Steel Containers and Packaging” is published at 211 cents per kilogram.
Real packs usually land in a dearer category, so use the calculator for Oregon and Yukon.
Deadlines in Oregon and Yukon
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 |
| Yukon | report | May 31 | the previous calendar year |
| Yukon | report | July 1 | the previous calendar year |
| Yukon | report | every three years, on or before September 1, beginning with the second annual report submitted for the program; not annual | verifies the annual report most recently submitted for the program |
The first annual report date is the same on both sides, May 31.
Penalties in Oregon and Yukon
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 Yukon
How the report file for Oregon compares with the one for Yukon.
| Aspect | Oregon | Yukon |
|---|---|---|
| Layout | Oregon producer supply report by material category 2026-09-29 (built from CAA Oregon 2026 fee schedule) | Yukon steward annual report Fee-year categories, reviewed 2026-09-29 |
| Recipient | Circular Action Alliance (Oregon PRO) | Government of Yukon / Circular Materials |
| How it is submitted | CAA producer portal. The customer signs in and submits. | WeRecycle Portal |
| 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 Yukon
Check the exemption thresholds before anything else. Yukon reaches smaller sellers than Oregon, so a seller that is exempt in Oregon may still have to register in Yukon.
Questions about comparing these two programmes
Is Oregon or Yukon stricter on packaging EPR?
Yukon exempts only producers below the lower revenue floor, CA$1,000,000 against $5,000,000 in Oregon. Both set the lowest weight exemption at 1 tonne. Both programmes set their first annual report for May 31. Yukon publishes the higher per-kilogram fee in 4 of 4 shared material classes.
Do I register in both Oregon and Yukon?
Oregon requires producers to register. Yukon has not yet published its registration duty.
How do the fees per kilogram compare in Oregon and Yukon?
Across 4 shared material classes, Yukon 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 Yukon?
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
- laws.yukon.ca: 2024 0019 retrieved
Original wording: On or before May 31 of each year, a steward must
Original wording: completed year of less than $1,000,000,
Original wording: (A) the brand holder of the product, if the brand holder is resident in Canada,
Original wording: imported into or supplied in Yukon in the most recently completed year less than one tonne of designated materials
Original wording: On or before May 31 of each year, a steward must submit the records described in paragraphs (1)(d) to (f)
Original wording: On or before July 1 of each year, the operator of a stewardship program must
Original wording: Every three years, the operator of a program must submit an audit report on or before September 1
- circularmaterials.ca: Circular Materials Report to Producers 2025 retrieved
Original wording: Average fee rate (cents per kg) (Total fee budget/supply tonnes) 227 c/kg
- 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
- knowledge.werecycle.ca: Report to Producers 2026 OCT15 retrieved
Original wording: Circular Materials in the Yukon Fee Schedule (Cents/Kg)
Original wording: Boxboard and Other Paper Packaging 136 127 7.1 %
Original wording: LDPE/HDPE Film 588 566 3.9%
Original wording: Clear Glass 122 116 5.2%
Original wording: Other Steel Containers and Packaging 211 191 10.5%
The free plan is enough to start. We estimate and prepare; you sign and submit.