Washington vs Yukon EPR: Rules Compared
Last verified
Washington 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 Washington. Washington has the lower weight floor, 907.2 kg against 1 tonne in Yukon. Both programmes set their first annual report for May 31.
Washington and Yukon side by side
3 of 9 rows have a verified figure on each side of Washington 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 | Washington | 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 | 907.2 kg | 1 tonne | Washington |
| 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 | not yet published | 136 cents per kilogram | Not comparable |
| Plastic fee, cheapest matched rate | not yet published | 588 cents per kilogram | Not comparable |
The lowest revenue exemption is $5,000,000 in Washington 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 Washington but still in scope in Yukon.
The lowest weight exemption is 907.2 kg of packaging in Washington and 1 tonne in Yukon, about 1.1 times as much in Yukon as in Washington. A seller whose packaging falls between the two lines is exempt in Yukon but counted in Washington.
The first annual report date is the same on both sides, May 31.
Who runs the programme in Washington and Yukon
Who collects and who the producer files with, in Washington and then Yukon.
| Aspect | Washington | Yukon |
|---|---|---|
| Regime | Washington Recycling Reform Act, chapter 70A.208 RCW | Extended Producer Responsibility Regulation, OIC 2024/19 (effective 2024-01-25; launched 2025-11-01) |
| Regulator | Washington State Department of Ecology | Government of Yukon, Ministry of the Environment |
| Producers obligated | Yes | Yes |
| Registration | Required, Producer registers with a PRO; the PRO registers with Ecology | not yet published |
| Producer organisation | one producer responsibility organisation: Circular Action Alliance; membership required | one producer responsibility organisation: Circular Materials; membership required |
| Revenue counted as | worldwide gross revenue, USD, prior fiscal year | gross revenue inside the jurisdiction, CAD, completed year |
| Who counts as the producer | primary: manufacturer, brand licensee, brand owner, importer | 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 Washington and Yukon therefore sit in thresholds, fees, dates and report formats rather than in whom a producer deals with.
What Washington and Yukon cover, side by side
Each row below is one published feature of the two programmes; a cell reads “not yet published” when Washington or Yukon has no verified entry for it in the dataset.
| Aspect | Washington | Yukon |
|---|---|---|
| Materials covered | packaging, paper products | not yet published |
| Product classes covered | packaging, paper | not yet published |
| Excluded from scope | exempt materials | not yet published |
| Sales channels addressed | physical retail, remote sale, other distribution | not yet published |
| Producer duty: primary packaging | manufacturer; licensee; brand_owner; importer | brand_owner; importer; seller; marketplace |
| Exemption 1 | A de minimis producer is under one ton, or under the global revenue limit, or an agricultural employer within limits. | Charity, under CAD 1,000,000 Yukon revenue or under one tonne |
| Exemption 2 | Registered 501(c)(3) and 501(c)(4) organizations are excluded from the producer definition. | not yet published |
| Producer duty: secondary packaging | not yet published | brand_owner; importer; seller; marketplace |
| Producer duty: tertiary packaging | not yet published | brand_owner; importer; seller; marketplace |
| Producer duty: shipping packaging | not yet published | brand_owner; importer; seller; marketplace |
| Producer duty: service packaging | not yet published | seller; marketplace |
| Producer duty: other packaging | not yet published | brand_owner; importer; seller; marketplace |
| Reporting categories | not yet published | 36, material category |
Thresholds and exemptions in Washington and Yukon
Every verified threshold Washington and Yukon publish, as each states it.
| Place | Measure | Amount | Effect | Basis as published |
|---|---|---|---|---|
| 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 |
| Yukon | revenue | CA$1,000,000 | exempt below | revenue in Yukon |
| Yukon | packaging tonnage | 1 tonne | exempt below | supply |
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.
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 Washington 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 Washington but still in scope in Yukon.
The lowest weight exemption is 907.2 kg of packaging in Washington and 1 tonne in Yukon, about 1.1 times as much in Yukon as in Washington. A seller whose packaging falls between the two lines is exempt in Yukon but counted in Washington.
Fees per kilogram for shared materials
Yukon publishes per-kilogram rates in the dataset; Washington does not. The rows therefore show Yukon only. Until both sides publish per-kilogram rates for the same material class, a fee comparison between Washington and Yukon would mean inventing a figure, and this page does not do that.
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.
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.
Deadlines in Washington and Yukon
Each verified date, with the period it covers when one is given.
| Place | Kind | Date | Covers |
|---|---|---|---|
| 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 |
| 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 Washington and Yukon
What each side has published; a side without an amount says so.
Washington penalty for producer violating chapter 70A.208 RCW: up to $1,000 per day.
Report formats in Washington and Yukon
How the report file for Washington compares with the one for Yukon.
| Aspect | Washington | Yukon |
|---|---|---|
| Layout | Washington interim producer supply report by material class 2026-09-29 (interim, built from CAA guidance) | Yukon steward annual report Fee-year categories, reviewed 2026-09-29 |
| Recipient | Circular Action Alliance (Washington 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, Washington or Yukon
Check the exemption thresholds before anything else. Yukon reaches smaller sellers than Washington, so a seller that is exempt in Washington may still have to register in Yukon.
Questions about comparing these two programmes
Is Washington or Yukon stricter on packaging EPR?
Yukon exempts only producers below the lower revenue floor, CA$1,000,000 against $5,000,000 in Washington. Washington has the lower weight floor, 907.2 kg against 1 tonne in Yukon. Both programmes set their first annual report for May 31.
Do I register in both Washington and Yukon?
Washington requires producers to register. Yukon has not yet published its registration duty.
How do the fees per kilogram compare in Washington and Yukon?
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, Washington or Yukon?
The first annual report date is the same on both sides, May 31.
How these figures are made
Sources
- 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.
- 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
- 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%
The free plan is enough to start. We estimate and prepare; you sign and submit.