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Sell on Amazon EPR Oregon: who is the producer?

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For Amazon sales in Oregon, the sourced hierarchy names the manufacturer or brand owner, brand licensee and importer as the producer of primary packaging. It adds secondary (manufacturer or brand owner, brand licensee and importer) and shipping (packer and shipper). Instica estimates which role fits your sales and prepares the data; you confirm the role, then sign and submit.

Flow of producer roles by packaging level for Amazon sales in OregonAmazon: 1. primary: manufacturer or brand owner > brand licensee > importer *; 2. secondary: manufacturer or brand owner > brand licensee > importer; 3. shipping: packer and shipper; 4. service: first distributor; 5. other: first distributorAmazonprimarymanufacturer or brandowner > brand licensee >importersecondarymanufacturer or brandowner > brand licensee >importershippingpacker and shipperservicefirst distributorotherfirst distributor
Source: Oregon producer hierarchy, retrieved 2026-09-29

Who is the producer for Amazon sales in Oregon?

A packaging producer is not one business for every pack. The hierarchy for Oregon assigns a role at each packaging level, and 6 levels have roles named in the sourced text. Amazon sales touch 5 of them in Instica’s grouping, so the table below shows every level and marks the ones that apply to this channel.

Producer roles by packaging level in Oregon
Packaging levelRoles named in the hierarchyFor Amazon
primarymanufacturer or brand owner, brand licensee and importerApplies to Amazon sales
secondarymanufacturer or brand owner, brand licensee and importerApplies to Amazon sales
tertiaryfirst distributorNot part of a typical Amazon order
shippingpacker and shipperApplies to Amazon sales
servicefirst distributorApplies to Amazon sales
otherfirst distributorApplies to Amazon sales

Oregon: at the primary packaging level the producer hierarchy names the manufacturer or brand owner, brand licensee and importer (2025).

Primary packaging is the pack that directly holds the item and reaches the customer with it: the bag, jar, bottle, can or wrapper. For Amazon sales the hierarchy assigns it to the manufacturer or brand owner, brand licensee and importer, in that order of precedence.

Oregon: at the secondary packaging level the producer hierarchy names the manufacturer or brand owner, brand licensee and importer (2025).

Secondary packaging groups or presents primary packs, such as an outer box, a sleeve or a multipack carton. For Amazon sales the hierarchy assigns it to the manufacturer or brand owner, brand licensee and importer, in that order of precedence.

Oregon: at the tertiary packaging level the producer hierarchy names the first distributor (2025).

Tertiary packaging moves goods in bulk: pallets, stretch wrap, corner boards and outer cartons for warehouse and freight. For Amazon sales the hierarchy assigns it to the first distributor.

Oregon: at the shipping packaging level the producer hierarchy names the packer and shipper (2025).

Shipping packaging is what an order travels in to the customer: the mailer or shipping box, void fill, tape and labels. For Amazon sales the hierarchy assigns it to the packer and shipper.

Oregon: at the service packaging level the producer hierarchy names the first distributor (2025).

Service packaging is supplied at the point of sale to hand goods over, such as carrier bags, takeaway containers and gift wrap. For Amazon sales the hierarchy assigns it to the first distributor.

Oregon: at the other packaging level the producer hierarchy names the first distributor (2025).

The hierarchy also assigns a residual level for packaging that does not fit the other levels, usually to whoever first distributes it. For Amazon sales the hierarchy assigns it to the first distributor.

The roles above are defined by the law, not by the channel. This is what each one means for a seller whose orders come through Amazon, and the tests below are the questions to answer about your own business. For a seller on Amazon the role is a question of facts: who made the product, whose brand is on it, who packs and ships the order and whether it was brought into the jurisdiction. You answer those questions in the workspace, Instica reads the hierarchy against them, and you confirm the result.

manufacturer or brand owner
The manufacturer or brand owner is the maker of the packaged product when it is sold under the maker’s own brand or with no brand shown. Look at the label: if your name or brand is the one on the pack, or no brand is shown and you made it, this role is yours.
brand licensee
The brand licensee is a business that sells under a brand it licenses from the brand owner. Look at the licence: if you pay to use another owner’s brand on goods you sell, the hierarchy treats you as the licensee.
importer
The importer is the business that brings the packaged goods, or the packaging itself, into the jurisdiction. Look at where the goods came from: stock that crossed the border to reach you makes you the importer for that stock.
packer and shipper
The packer and shipper is the business that packs the order and ships it to the customer. Look at who closes the box: the business that packs the parcel and sends it holds this role for the shipping packaging.
first distributor
The first distributor is the business that first makes the packaged goods available in the jurisdiction. Look at who first made the goods available locally: if that was you, the role falls to you.

The statute or regulator text behind the Oregon hierarchy, in its source wording:

Original wording

the producer of the packaging is the person that manufactures the packaged item
Paraphrase: Physical retail: the manufacturer of the packaged item if sold under its own brand or with no brand shown, else the brand or trademark licensee, else the US importer (ORS 459A.866(1)(a)). Remote sale: packaging that protects or contains the item follows the retail rule; shipping packaging goes to the person that packages and ships the item (1)(b). All other packaging goes to the person that first distributes the packaged item in or into Oregon (1)(c). Printing and writing paper: the publisher for magazines, newspapers, catalogs and similar, else manufacturer, brand owner or licensee, else importer (2). Food serviceware: the person that first sells it in or into Oregon (3). Oregon has no separate brand-owner tier at retail.

Source: oregon.public.law: ors 459A.866

What Amazon changes about the answer

The hub for Oregon gives the default answer, primary: manufacturer or brand owner > brand licensee > importer. For Amazon sales the outcome is primary: manufacturer or brand owner > brand licensee > importer; secondary: manufacturer or brand owner > brand licensee > importer; shipping: packer and shipper; service: first distributor; other: first distributor. The difference is the secondary, shipping, service and other levels, which an order placed through Amazon brings into scope and a plain in-store sale does not.

Instica groups the packaging levels an order placed through Amazon produces as primary, secondary, shipping, service and other. That grouping is our reading of how the channel ships goods, not wording from the law, and it is what makes the outcome here different from the default.

Amazon sellers either ship orders themselves or send stock to fulfilment centres, so the same business can be the packer of a shipping carton on one order and only the brand owner on the next. The order and shipment reports record the destination country and state of each order, which is the data a regional estimate needs.

For Amazon sales in Oregon, the producer outcome is primary: manufacturer or brand owner then brand licensee then importer.

For Amazon sales in Oregon, the producer outcome is secondary: manufacturer or brand owner then brand licensee then importer.

For Amazon sales in Oregon, the producer outcome is shipping: packer and shipper.

For Amazon sales in Oregon, the producer outcome is service: first distributor.

For Amazon sales in Oregon, the producer outcome is other: first distributor.

Oregon lists these sales routes as in scope: physical retail, remote sale and other distribution.

Oregon treats these sales routes as in scope: physical retail, remote sale and other distribution. Orders placed through Amazon reach the customer remotely, so the remote-sale wording is the one to read.

Does a small-seller threshold apply in Oregon?

4 thresholds are published for Oregon. A threshold can exempt a small producer, trigger registration or move a producer to a lighter regime, so check these before anything else as a seller on Amazon.

Thresholds published for Oregon
MeasureAmountEffectBasis
revenue$5,000,000exempt below the thresholdgross revenue, most recent fiscal year
tonnage1 metric tonexempt below the thresholdcovered products sold in or into Oregon, most recent calendar year
tonnage5 metric tonsexempt below the thresholdcovered products, including secondary and tertiary packaging for beverage containers, most recent calendar year
revenue$10,000,000flat fee bandgross revenue, most recent fiscal year, or under 5 metric tons sold in or into Oregon

Oregon threshold on revenue: $5,000,000; effect: exempt below the threshold.

Oregon threshold on tonnage: 1 metric ton; effect: exempt below the threshold.

Oregon threshold on tonnage: 5 metric tons; effect: exempt below the threshold.

Oregon threshold on revenue: $10,000,000; effect: flat fee band.

Oregon measures revenue as organisation gross revenue in USD, over the fiscal year.

The way Oregon counts revenue is set out above. Sales through several channels are added together, so one storefront alone may not tell you where you stand.

Marketplace sales count toward your totals even when the marketplace handles fulfilment, because the thresholds measure what you put on the market, not who drove the van.

Registration and the organisation in Oregon

Once you know you are the producer, the next questions are where to register and with whom. The facts below are the sourced answers for Oregon; Instica prepares the data, and you register and report yourself.

Oregon: producers must register through Circular Action Alliance producer portal (PRO registration); DEQ holds no separate producer registry.

The registration point is Circular Action Alliance producer portal (PRO registration); DEQ holds no separate producer registry (https://circularactionalliance.org/registration). Instica never stores your login for it and never files for you.

Oregon organises producer responsibility through a single producer responsibility organisation: Circular Action Alliance; membership is required.

Oregon uses a single producer responsibility organisation. Instica estimates your fees; the organisation invoices you.

Oregon allows a producer’s obligation to be transferred to another party.

A transfer lets another party take on your obligation; the source says Another person registers with a PRO as the responsible producer for the covered product. If you sell through Amazon, ask whether the other party is willing before you rely on it.

Exemptions listed for Oregon

Oregon lists 3 exemptions. An exemption is a rule in the source, so Instica quotes it rather than judging whether you qualify.

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.

Whether an exemption fits a business selling on Amazon depends on your totals across every channel, not on Amazon alone.

Dates that matter in Oregon

4 dates are published for Oregon. Dates come from the regulator or the organisation, and each one shows what it covers.

Dates published for Oregon
KindDateCoversNote
reportMay 31, 2026calendar year 2025Internal CAA deadline that lets CAA set 2027 fees. The Oregon rule set the 2024-data deadline of 31 March 2025 (OAR 340-090-0870).
otherJuly 1, 2025—The approved PRO could begin charging membership fees from this date.
otherJanuary 1, 2027—The next claims window opens in January 2027. The close date is not yet published.
reportDecember 31, 2026—Applies only to the 25 largest producers by weight. Life cycle impact evaluation on 1% of covered products, biennially.

Oregon: report date May 31, 2026, covering calendar year 2025.

Oregon: other date July 1, 2025.

Oregon: other date January 1, 2027.

Oregon: report date December 31, 2026.

Marketplace order reports are available on demand, so the quickest way to be ready for a reporting date is to export the last period’s orders and check the destination split early.

Penalties in Oregon

One penalty is published for Oregon.

Oregon penalty for failing to register or become a member of a producer responsibility organization: up to $25,000 per day.

Penalties are quoted from the source. Instica does not predict whether one will be applied to you.

What Amazon data Instica reads

Instica reads 2 exports from Amazon and maps each column to the fields an estimate needs: the order, the SKU, the quantity and where the order was sent. The destination is what splits your units by jurisdiction.

How the Amazon order report (All Orders) maps to Instica fields
Instica fieldColumn in the exportNeeded
Fulfilmentfulfillment-channelOptional
Item statusitem-statusOptional
Marketplacesales-channelOptional
Order datepurchase-dateRequired
Order numberamazon-order-idRequired
QuantityquantityRequired
Ship-to countryship-countryOptional
Ship-to postcodeship-postal-codeOptional
Ship-to state or regionship-stateOptional
SKUskuRequired
Order statusorder-statusOptional

Instica maps 11 columns of the Amazon order report (All Orders) (tab-separated) to its own fields.

The Amazon order report (All Orders) needs Order number, Order date, SKU and Quantity to be mapped before an estimate can run.

Amazon marketplace sites map to destination countries as follows: amazon.ca → CA, amazon.co.uk → GB, amazon.com → US, amazon.com.be → BE, amazon.de → DE, amazon.es → ES, amazon.fr → FR, amazon.ie → IE, amazon.it → IT, amazon.nl → NL, amazon.pl → PL and amazon.se → SE.

How the Amazon FBA fulfilled shipments report maps to Instica fields
Instica fieldColumn in the exportNeeded
Marketplacesales-channelOptional
Order dateshipment-date / purchase-dateRequired
Order numberamazon-order-idRequired
Quantityquantity-shipped / quantityRequired
Ship-to countryship-countryOptional
Ship-to postcodeship-postal-codeOptional
Ship-to state or regionship-stateOptional
SKUskuRequired

Instica maps 8 columns of the Amazon FBA fulfilled shipments report (tab-separated) to its own fields.

The Amazon FBA fulfilled shipments report needs Order number, Order date, SKU and Quantity to be mapped before an estimate can run.

Amazon marketplace sites map to destination countries as follows: amazon.ca → CA, amazon.co.uk → GB, amazon.com → US, amazon.com.be → BE, amazon.de → DE, amazon.es → ES, amazon.fr → FR, amazon.ie → IE, amazon.it → IT, amazon.nl → NL, amazon.pl → PL and amazon.se → SE.

Orders are matched to Oregon by the ship-to state or region column. Rows outside your chosen jurisdictions are left out of this page’s estimate and counted elsewhere.

An export from Amazon carries the destination of every order, so one file can feed estimates for Oregon and every other jurisdiction your orders reach.

What to do next as a seller on Amazon

  1. Confirm your role for Amazon sales in Oregon against the table above.
  2. Check the thresholds and exemptions with your total sales across every channel.
  3. Review how Circular Action Alliance registers and invoices producers.
  4. Export your Amazon orders and let Instica match the destinations and estimate the weights.
  5. Review the estimate, correct any figure you know better, then sign and submit the report yourself at the registration point.

Instica measures, estimates and prepares the Amazon data. It does not decide your role, sign for you or submit anything.

Questions sellers ask

Am I the producer if I sell on Amazon in Oregon?

It depends on the facts of each product. The sourced hierarchy for Oregon names the manufacturer or brand owner, brand licensee and importer for primary packaging. If you made the product, own its brand or imported it, you are probably in that list; if you only resell another brand’s goods, someone else may be the producer. Instica estimates the likely role from your answers and you confirm it.

Does Amazon register or report for me?

The hierarchy for Oregon does not name the marketplace as a producer, so plan on registering and reporting yourself or through a party you appoint.

What is different about Amazon compared with selling in a shop?

An order placed through Amazon is shipped to the customer, so shipping packaging enters the picture. For Oregon the outcome is primary: manufacturer or brand owner > brand licensee > importer; secondary: manufacturer or brand owner > brand licensee > importer; shipping: packer and shipper; service: first distributor; other: first distributor. The hub for Oregon describes the default for primary packaging only.

Is there a size threshold for Amazon sellers in Oregon?

Oregon threshold on revenue: $5,000,000; effect: exempt below the threshold. The threshold counts all your sales, not only Amazon.

When is the next date I should know about?

Oregon: report date May 31, 2026, covering calendar year 2025.

What happens if I do not register?

Oregon penalty for failing to register or become a member of a producer responsibility organization: up to $25,000 per day.

Do I need an organisation to handle this for me?

Oregon works through Circular Action Alliance. Instica estimates your fees and prepares your data; the organisation registers you and issues the invoice.

How these figures are made

Our reviewers.

Sources

  1. oregon.public.law: ors 459A.866 retrieved
    Original wording: the producer of the packaging is the person that manufactures the packaged item
  2. 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.
  3. 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
  4. 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: "Covered product" means: (A) Packaging; (B) Printing and writing paper; and (C) Food serviceware.
    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
  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. developer-docs.amazon: report type values order retrieved
    Original wording: amazon-order-id merchant-order-id purchase-date last-updated-date order-status order-item-id fulfillment-channel sales-channel order-channel ship-service-level product-name sku asin item-status quantity
  10. developer-docs.amazon: report type values fba retrieved
    Original wording: amazon-order-id merchant-order-id shipment-id shipment-item-id amazon-order-item-id merchant-order-item-id purchase-date payments-date shipment-date reporting-date buyer-email buyer-name buyer-phone-number sku product-name quantity-shipped
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