Oregon EPR 2027
Last verified
Oregon requires producers who place packaging on the market to meet packaging EPR duties under Oregon Recycling Modernization Act, ORS 459A.860 to 459A.975 (SB 582 of 2021). The regulator is Oregon Department of Environmental Quality (DEQ). We record 4 thresholds and 5 dated deadlines. 13 of 16 core rule fields are verified against primary sources.
The free plan is enough to start. We estimate and prepare; you sign and submit.
Packaging EPR in Oregon: what we have verified
This page collects what we have verified about packaging extended producer responsibility (EPR) in Oregon. 13 of 16 core rule fields are published from primary sources and 3 are not yet published. The dataset was last reviewed on September 29, 2026, and the newest source on this page was retrieved on November 5, 2026.
- Regime
- Oregon Recycling Modernization Act, ORS 459A.860 to 459A.975 (SB 582 of 2021)
- Regulator
- Oregon Department of Environmental Quality (DEQ)
- Producers obliged
- Yes
- System
- a single producer responsibility organisation
- Registration
- Required
- Fee schedules
- 2
The packaging EPR regime in Oregon is recorded as Oregon Recycling Modernization Act, ORS 459A.860 to 459A.975 (SB 582 of 2021).
The regulator named for Oregon is Oregon Department of Environmental Quality (DEQ).
Producers placing packaging on the market in Oregon carry a packaging EPR obligation.
Original wording
producers of products covered under Oregon's Recycling Modernization Act (packaging, paper, and food serviceware)Source: Regime
Who is the producer in Oregon
In Oregon, packaging EPR obliges producers to organise or fund the collection and recycling of the packaging they place on the market. The sections below set out who counts as the producer, which thresholds decide whether a business is in scope, and what has to be filed.
The producer hierarchy decides who answers for a pack when several businesses touch it. For Oregon, the dataset names the following roles for each packaging level.
| Packaging level | Producer roles recorded |
|---|---|
| other packaging | first distributor |
| primary (sales) packaging | manufacturer or brand owner, licensee, importer |
| secondary packaging | manufacturer or brand owner, licensee, importer |
| service packaging | first distributor |
| shipping packaging | packer or shipper |
| tertiary (transport) packaging | first distributor |
In Oregon, the party that carries the obligation by default is the manufacturer or brand owner, licensee, and importer.
Original wording
the producer of the packaging is the person that manufactures the packaged itemSource: Producer hierarchy
In Oregon, the obligation can be transferred to another party under the stated rules.
Transfer detail: Another person registers with a PRO as the responsible producer for the covered product.
Whether affiliates are counted together in Oregon: not yet published. Reason: ORS 459A.863(32) does not say whether parent, subsidiary or affiliate revenue aggregates. The rule text (OAR 340-090-0840) was not read.
Where a revenue test applies in Oregon, it is measured on gross revenue of the organisation over fiscal year, in USD.
Roles matter because an online seller, an importer and a brand owner can each be the producer for the same pack, and a pack is counted once. If you sell into Oregon through a marketplace, check whether the marketplace or you are recorded as the obligated party. Confirm who is responsible for reporting.
Thresholds that apply in Oregon
Thresholds decide whether a business is in scope, whether it pays fees, or whether it can file a simplified report. Oregon publishes 4 verified thresholds.
| Measure | Amount | Effect | Note |
|---|---|---|---|
| revenue | below $5,000,000.00 | the producer is exempt below it | – |
| tonnage | below 1 metric ton | the producer is exempt below it | – |
| tonnage | below 5 metric tons | the producer is exempt below it | – |
| revenue | below $10,000,000.00 | a flat-fee band applies | – |
Oregon sets a revenue threshold of below $5,000,000.00; effect: the producer is exempt below it.
Basis of the revenue threshold: gross revenue, most recent fiscal year.
Original wording
Has a gross revenue of less than $5 million for the organization's most recent fiscal yearSource: Threshold
Oregon sets a tonnage threshold of below 1 metric ton; effect: the producer is exempt below it.
Basis of the tonnage threshold: covered products sold in or into Oregon, most recent calendar 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 yearSource: Threshold
Oregon sets a tonnage threshold of below 5 metric tons; effect: the producer is exempt below it.
Basis of the tonnage threshold: covered products, including secondary and tertiary packaging for beverage containers, most recent calendar year.
Original wording
that sold in or into Oregon less than five metric tons of covered productsSource: Threshold
Oregon sets a revenue threshold of below $10,000,000.00; effect: a flat-fee band applies.
Basis of the revenue threshold: gross revenue, most recent fiscal year, or under 5 metric tons sold in or into Oregon.
Original wording
a producer responsibility organization shall establish uniform membership fees for members that had a gross revenue of less than $10 millionSource: Threshold
Exemptions in Oregon
An exemption removes or reduces a duty for a defined group. Oregon lists 3 exemptions in the dataset. Some apply automatically; others only apply if you ask the regulator for them, usually within a window.
Exemption in Oregon: 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 applies without a separate application.
Original wording
A small producer is exempt from the requirement to be a member of a producer responsibility organizationSource: Exemption
Exemption in Oregon: 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 applies without a separate application.
Original wording
Covered product exemptions, meanwhile, are product-specific exemptions that exclude a given type of packagingSource: Exemption
Exemption in Oregon: 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. You must apply for it.
Application window: Claim window opens in Q1 of each year. The latest window was 6 Jan to 31 Mar 2026 (5 p.m. PT), applied to 2027 fees. The next opens in January 2027.
Original wording
The latest window for producers to submit claims for this exemption was Jan. 6 – March 31, 2026Source: Exemption
Registration and the system in Oregon
Registration is where an obligation becomes visible to the regulator. The records below show whether Oregon asks producers to register, with whom, and which organisation or scheme carries the collection and recycling system.
Producers in Oregon must register. How: Circular Action Alliance producer portal (PRO registration); DEQ holds no separate producer registry.
Who registers: The producer, with the PRO, after signing the Producer Participant Agreement and the Oregon addendum
Registry (opens the official registry page).
Original wording
In order to access CAA's data reporting portal, producers must first sign the Producer Participant Agreement with CAASource: Registration
In Oregon, the system runs through a single producer responsibility organisation: Circular Action Alliance; membership is required.
Original wording
Circular Action Alliance, at present, is Oregon's only approved Producer Responsibility OrganizationSource: Organisation
The packaging taxonomy in Oregon has 60 categories. Granularity: covered material type by material class.
Deadlines in Oregon
Oregon records 6 deadlines, 5 of them verified. This page gives the summary; every date, the period it covers and what it requires are on the deadlines page for Oregon.
The next dated obligation we hold for Oregon falls on December 31, 2026. 1 more dated obligation follows it.
1 obligation recurs on a fixed day each year rather than on a single date.
See every deadline for Oregon, with its period and what it requires, on the Oregon deadlines page.
A deadline is a date the regulator published, not a date we set. We can estimate what you may owe and prepare the report file; you sign and submit it in the regulator's own portal.
Fees and reporting in Oregon
Oregon publishes 2 fee schedules, for fee years 2026 and 2027. The schedule sets what each kind of packaging costs; the rates themselves are on the fee pages, not here.
The 2026 schedule is based on packaging placed on the market from January 1, 2024 to December 31, 2024.
The 2027 schedule is based on packaging placed on the market from January 1, 2025 to December 31, 2025.
- Oregon 2026 fees: rates by material for fee year 2026.
- Oregon 2027 fees: rates by material for fee year 2027.
The report you file is a defined file or form. Oregon records 1 format; we prepare the file to that specification and you upload it yourself.
Oregon producer supply report by material category is a csv file submitted through CAA producer portal. The customer signs in and submits. The customer reviews, signs and submits it.
Columns, material mapping and the checks a file must pass are on the Oregon report format page.
Oregon: packaging fees by material
Instica groups the verified rates of the 2027 Circular Action Alliance (Oregon PRO) schedule for Oregon into 5 material classes. For each class the table gives the lowest and highest published rate in US cents per pound and the unweighted mean in USD per tonne, with a link to the source the rates were read from, retrieved October 22, 2026.
| Material | Categories | Lowest (US cents per pound) | Highest (US cents per pound) | Mean (USD per tonne) | Source |
|---|---|---|---|---|---|
| Wood and organics | 1 | 48.0 | 48.0 | 1,058.22 | Source |
| Glass | 2 | 0.0 | 83.0 | 914.92 | Source |
| Plastic | 35 | -4.0 | 78.0 | 825.16 | Source |
| Other metal | 9 | -9.0 | 36.0 | 448.27 | Source |
| Paper and card | 15 | 0.0 | 43.0 | 214.58 | Source |
Instica holds 2 schedules for Oregon priced in the same currency, from 2026 to 2027. The table gives the unweighted mean per tonne of each material class in each schedule, and the change from the earliest schedule in which the class appears to the latest.
| Material | 2026 | 2027 | Change | Source |
|---|---|---|---|---|
| Paper and card | 341.72 | 214.58 | -37.2 % | Source |
| Glass | 1,333.80 | 914.92 | -31.4 % | Source |
| Other metal | 984.73 | 448.27 | -54.5 % | Source |
| Plastic | 1,363.62 | 825.16 | -39.5 % | Source |
| Wood and organics | 2,314.85 | 1,058.22 | -54.3 % | Source |
The same material classes in the 3 jurisdictions that publish a per-weight schedule in USD, Oregon included. For each class the table gives the mean here, the median of the other jurisdictions, the rank of Oregon (1 is the highest) and the jurisdiction with the highest mean.
| Material | This jurisdiction | Median of the others | Rank | Highest mean | Source |
|---|---|---|---|---|---|
| Wood and organics | 1,058.22 | 1,940.07 | 2 / 2 | Colorado: 1,940.07 | Source |
| Glass | 914.92 | 661.39 | 1 / 2 | Oregon: 914.92 | Source |
| Plastic | 825.16 | 1,373.48 | 2 / 2 | Colorado: 1,373.48 | Source |
| Other metal | 448.27 | 600.15 | 2 / 2 | Colorado: 600.15 | Source |
| Paper and card | 214.58 | 361.56 | 2 / 2 | Colorado: 361.56 | Source |
Labelling, languages, targets and penalties in Oregon
Labelling in Oregon: not yet published. Reason: The DEQ summary of producer obligations lists registration, reporting and fees and no labelling duty. ORS 459A.860 to 459A.975 was not searched line by line for a marking rule, so absence is unconfirmed.
Languages in Oregon: not yet published. Reason: No page states the filing language of the CAA portal. DEQ publishes a Spanish summary of producer obligations, but filings go to a private PRO. English is recorded as the working assumption.
Oregon sets a target for statewide plastic recycling rate: 25 percent by December 31, 2028.
Oregon sets a target for statewide plastic recycling rate: 50 percent by December 31, 2040.
Oregon sets a target for statewide plastic recycling rate: 70 percent by December 31, 2050.
Oregon sets a penalty for failing to register or become a member of a producer responsibility organization: up to $25,000 per day. Escalation: Class 1 violation, up to this amount.
Labelling, language, target and penalty rules are the parts of a regime that are easiest to miss. A report filed in the wrong language or a pack without a required mark can cost as much as a late payment, so read each of these against your own products.
Oregon compared with nearby places
Rules do not stop at a border. A business that sells into Oregon usually sells into its neighbours too, and the thresholds and deadlines differ. The table reads Oregon against the places closest to it that have verified data.
Oregon read against each neighbour
Each paragraph reads Oregon against one place from the table above, using only records verified for both. A part is left out when either side is not yet published.
Oregon and California both record an obligation for packaging producers. The regulator is Oregon Department of Environmental Quality (DEQ) in Oregon and CalRecycle (Department of Resources Recycling and Recovery), through its PEPRS portal next door. Both run a single producer responsibility organisation. Registration is required in both. The first threshold is $5,000,000.00 of revenue in Oregon against $1,000,000.00 of revenue in California, so a small seller can be in scope next door while below the line here. The earliest recorded deadline is July 1, 2025 in Oregon and January 1, 2027 in California, 549 days earlier here.
Oregon and Washington both record an obligation for packaging producers. The regulator is Oregon Department of Environmental Quality (DEQ) in Oregon and Washington State Department of Ecology next door. Both run a single producer responsibility organisation. Registration is required in both. The first thresholds are measured differently: $5,000,000.00 of revenue in Oregon and 1 short ton of tonnage in Washington, so the figures cannot be compared directly. The earliest recorded deadline is July 1, 2025 in Oregon and March 1, 2026 in Washington, 243 days earlier here.
Oregon and Colorado both record an obligation for packaging producers. The regulator is Oregon Department of Environmental Quality (DEQ) in Oregon and Colorado Department of Public Health and Environment (CDPHE), Solid Waste and Materials Management Program next door. Oregon runs a single producer responsibility organisation, while Colorado runs more than one producer responsibility organisation. Registration is required in both. The first threshold is the same in both, $5,000,000.00 of revenue. The earliest recorded deadline is July 1, 2025 in Oregon and January 1, 2026 in Colorado, 184 days earlier here.
Oregon and Maine both record an obligation for packaging producers. The regulator is Oregon Department of Environmental Quality (DEQ) in Oregon and Maine Department of Environmental Protection next door. Both run a single producer responsibility organisation. Registration is required in both. The first threshold is $5,000,000.00 of revenue in Oregon against $2,000,000.00 of revenue in Maine, so a small seller can be in scope next door while below the line here. The earliest recorded deadline is July 1, 2025 in Oregon and May 31, 2027 in Maine, 699 days earlier here.
Oregon and Minnesota both record an obligation for packaging producers. The regulator is Oregon Department of Environmental Quality (DEQ) in Oregon and Minnesota Pollution Control Agency next door. Both run a single producer responsibility organisation. Registration is required in both. The first thresholds are measured differently: $5,000,000.00 of revenue in Oregon and 1 short ton of tonnage in Minnesota, so the figures cannot be compared directly. The earliest recorded deadline is July 1, 2025 in Oregon and May 31, 2026 in Minnesota, 334 days earlier here.
Oregon and Maryland both record an obligation for packaging producers. The regulator is Oregon Department of Environmental Quality (DEQ) in Oregon and Maryland Department of the Environment next door. Both run a single producer responsibility organisation. Registration is required in both. The first thresholds are measured differently: $5,000,000.00 of revenue in Oregon and 1 short ton of tonnage in Maryland, so the figures cannot be compared directly. The earliest recorded deadline is July 1, 2025 in Oregon and May 31, 2026 in Maryland, 334 days earlier here.
Oregon and United Kingdom both record an obligation for packaging producers. The regulator is Oregon Department of Environmental Quality (DEQ) in Oregon and Four environmental regulators (Environment Agency, Natural Resources Wales, SEPA, NIEA); PackUK is the scheme administrator that sets fees next door. Oregon runs a single producer responsibility organisation, while United Kingdom runs registered schemes that producers join. Registration is required in both. The first thresholds are measured differently: $5,000,000.00 of revenue in Oregon and 25 tonnes of tonnage in United Kingdom, so the figures cannot be compared directly. The earliest recorded deadline is July 1, 2025 in Oregon and October 1, 2026 in United Kingdom, 457 days earlier here.
Oregon and Belgium both record an obligation for packaging producers. The regulator is Oregon Department of Environmental Quality (DEQ) in Oregon and Interregional Packaging Commission (IVC-CIE, now EPRiBEL) next door. Oregon runs a single producer responsibility organisation, while Belgium runs more than one producer responsibility organisation. Registration is required in both. The first thresholds are measured differently: $5,000,000.00 of revenue in Oregon and 300 tonnes of single-use packaging per year of tonnage in Belgium, so the figures cannot be compared directly. The earliest recorded deadline is July 1, 2025 in Oregon and August 12, 2026 in Belgium, 407 days earlier here.
Where Oregon sits among the places we cover
Counted by verified core records, Oregon holds 13 of 17 and ranks 3 of 53 places in the dataset. The places just ahead of it are United Kingdom Plastic Packaging Tax (14) and United Kingdom (13). The places just behind it are Belgium (12), Ontario (12), Italy (12), California (12), Austria (11) and British Columbia (11).
Counting every verified record, not only the core fields, Oregon holds 25 and ranks 3 of 53. Ahead of it are Ontario (27) and Austria (26). Behind it are United Kingdom (24), United Kingdom Plastic Packaging Tax (24), Belgium (22), Washington (22), Québec (21) and British Columbia (20).
All 7 places in this region in the dataset record an obligation, so Oregon is not an outlier among its neighbours.
Ordered by earliest verified deadline, Oregon comes 5 of 41, on July 1, 2025. Before it come Austria (January 1, 2023, 912 days earlier), Czechia (January 1, 2023, 912 days earlier), Nova Scotia (January 1, 2024, 547 days earlier) and New Brunswick (June 30, 2025, 1 day earlier). After it come Colorado (January 1, 2026, 184 days later), Washington (March 1, 2026, 243 days later), Ontario (May 31, 2026, 334 days later), Québec (May 31, 2026, 334 days later), Maryland (May 31, 2026, 334 days later) and Minnesota (May 31, 2026, 334 days later).
Among places whose first threshold is also counted in revenue, Oregon sits 4 of 4 from the lowest. The table sets it beside the places just below and just above.
| Place | First threshold | Against this page |
|---|---|---|
| California | $1,000,000.00 | Lower |
| Maine | $2,000,000.00 | Lower |
| Colorado | $5,000,000.00 | Equal |
| Oregon | $5,000,000.00 | This page |
What is still open for Oregon
Oregon has 3 of 16 core fields still open, and the reason recorded for each is below.
- Treatment of affiliates
- Reason recorded: ORS 459A.863(32) does not say whether parent, subsidiary or affiliate revenue aggregates. The rule text (OAR 340-090-0840) was not read.
- Labelling
- Reason recorded: The DEQ summary of producer obligations lists registration, reporting and fees and no labelling duty. ORS 459A.860 to 459A.975 was not searched line by line for a marking rule, so absence is unconfirmed.
- Filing languages
- Reason recorded: No page states the filing language of the CAA portal. DEQ publishes a Spanish summary of producer obligations, but filings go to a private PRO. English is recorded as the working assumption.
Questions about packaging EPR in Oregon
Do I need to take part in packaging EPR in Oregon?
Oregon records a packaging EPR obligation for producers, with thresholds that decide who is in scope; compare your figures with the thresholds table. Whether you are the producer depends on the roles listed for each packaging level.
Who is the regulator in Oregon?
The regulator recorded for Oregon is Oregon Department of Environmental Quality (DEQ).
Is there a small-business threshold in Oregon?
Oregon records 4 verified thresholds; see the table above for the amounts and what each one changes.
When are filings due in Oregon?
Oregon records 5 verified deadlines; they are listed with the period each covers.
Do I have to register in Oregon?
Yes, the dataset records that registration is required in Oregon.
Does Instica file my report?
No. We measure your packaging, estimate what you may owe and prepare the report file. You review it, sign it and submit it yourself, and Instica never stores regulator-portal credentials.
How do I know the data is current?
Each record shows the source address and the date we retrieved it. This page was last verified on September 29, 2026.
Can I rely on this page for a decision?
It summarizes published sources to help you prepare. For a decision that carries real risk, ask the regulator or a qualified adviser.
Records behind the comparison
The regime in California is recorded as California SB 54, Plastic Pollution Prevention and Packaging Producer Responsibility Act (Public Resources Code, Division 30, Part 3, Chapter 3.1).
California runs its system through a single producer responsibility organisation: Circular Action Alliance.
California sets a revenue threshold of below $1,000,000.00.
California has a registration deadline on January 1, 2027.
The regime in Washington is recorded as Washington Recycling Reform Act, chapter 70A.208 RCW.
Washington runs its system through a single producer responsibility organisation: Circular Action Alliance.
Washington sets a tonnage threshold of below 1 short ton.
Washington has a deadline of another kind on March 1, 2026.
The regime in Colorado is recorded as Colorado Producer Responsibility Program for Statewide Recycling Act, C.R.S. 25-17-701 et seq. (HB22-1355).
Colorado runs its system through more than one producer responsibility organisation: Circular Action Alliance and Interchange 360 (automotive lubricant packaging, individual programme).
Colorado sets a revenue threshold of below $5,000,000.00.
Colorado has a payment deadline on January 1, 2026.
The regime in Maine is recorded as Maine Stewardship Program for Packaging, 38 M.R.S. section 2146.
Maine runs its system through a single producer responsibility organisation.
Maine sets a revenue threshold of below $2,000,000.00.
Maine has a reporting deadline on May 31, 2027.
The regime in Minnesota is recorded as Minnesota packaging EPR law, Minnesota Statutes sections 115A.144 to 115A.1463.
Minnesota runs its system through a single producer responsibility organisation: Circular Action Alliance.
Minnesota sets a tonnage threshold of below 1 short ton.
Minnesota has a registration deadline on July 1, 2026.
The regime in Maryland is recorded as Maryland packaging and paper products producer responsibility law (SB 901, 2025).
Maryland runs its system through a single producer responsibility organisation: Circular Action Alliance.
Maryland sets a tonnage threshold of below 1 short ton.
Maryland has a registration deadline on May 31, 2026.
The regime in United Kingdom is recorded as Extended producer responsibility (EPR) for packaging, under the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024.
United Kingdom runs its system through registered schemes that producers join.
United Kingdom sets a tonnage threshold of above 25 tonnes.
United Kingdom has a reporting deadline on October 1, 2026.
The regime in Belgium is recorded as Belgian interregional Cooperation Agreement on packaging waste, in force in its current version since 5 March 2020; enforced by the Interregional Packaging Commission (IRPC/IVC-CIE).
Belgium runs its system through more than one producer responsibility organisation: Fost Plus (household) and Valipac (industrial).
Belgium sets a tonnage threshold of 300 tonnes of single-use packaging per year.
Belgium has a deadline of another kind on September 15, 2026.
What to prepare for Oregon
- Work out whether you are the producer for each product you sell in Oregon, using the producer roles above.
- Compare your Oregon revenue and packaging weight with each threshold in the table; keep the working.
- Register with Circular Action Alliance producer portal (PRO registration); DEQ holds no separate producer registry before you report or pay.
- Put every dated deadline above in your calendar, with the period it covers.
- Collect packaging weights by material so the report file can be prepared to the format above.
- Sign and submit your filings yourself in the regulator's portal; Instica never stores portal credentials and never files for you.
Instica measures packaging, estimates what you may owe and prepares the report file. It does not decide whether you are obliged; that stays with you and the regulator.
How to read this page
Every statement on this page is generated from a verified record, and each record keeps its source address, the date we retrieved it, and, where the source is a statute or notice, the quoted text. A value marked "not yet published" has no verified source yet; we show the reason instead of a number.
Quotes are shown in the language of the source with a labelled summary in English. The summary helps you read; the quote is what the source says. If the two ever differ, the quote governs.
Oregon has 13 of 16 core fields verified. The remaining 3 are listed in the overview. When one of them is published, the page changes and the "last verified" date moves; until then, the safest assumption is that the answer is unknown, not that it is no.
What an open field means in practice
A field is marked not yet published when no primary source we can cite says what it needs to say. Below, each open field for Oregon is listed with the reason we recorded and what it means for a business that sells there while the field stays open.
- Treatment of affiliates
- Whether affiliates are added together affects group companies; keep group revenue and tonnage by entity.
- Labelling
- Labelling rules decide whether a pack needs a mark or a sorting instruction; check pack artwork before printing a large run.
- Filing languages
- The filing language decides whether you need a translation of your report; confirm before you prepare the file.
We re-check open fields when a source changes and when a reviewer flags one. If you hold a primary source that answers an open field for Oregon, the data-gaps page explains how to send it; we publish a field only after we can cite the source and its date.
What this means for different sellers in Oregon
Because Oregon records a packaging EPR obligation, each of the following sellers should expect to do some work. What differs is who the producer is and which threshold applies.
A brand owner that makes or packs its own goods
You are the likeliest producer. Count the packaging you put into Oregon by material, compare it with the thresholds, and register (the dataset records that registration is required). Keep the weights; every later step starts from them.
An importer or reseller of branded goods
Importers are named producers in many regimes. Check the producer roles above: if the importer is listed for a packaging level, the duty for that pack can move to you from the brand owner, and the brand owner may ask for proof that you handle it.
A seller that ships through an online marketplace
Some regimes make the marketplace answerable and some leave the duty with you. This page lists the roles recorded for Oregon; where the marketplace role is not listed, assume you remain responsible and check the marketplace's own seller guidance.
A small seller that sells only a few parcels a year
Compare your figures with the 4 verified thresholds above. Being under a threshold can mean no fee, a simplified report or only a registration; read the effect column, because it is not always full relief.
Common mistakes with Oregon packaging EPR
Most problems with packaging EPR do not come from the rule itself; they come from a few repeated slips. These are the ones to avoid when you work from the records for Oregon.
- Treating "not yet published" as "no". An open field means we do not know, and the safe reading is that a duty may exist.
- Using another place's threshold. Oregon sets its own figures (see the table); a neighbour's number does not carry over.
- Measuring in the wrong unit. Thresholds are written in kilograms, tonnes or a currency; convert before you compare.
- Counting the wrong period. The period a deadline covers is part of the rule, and the table shows it where it is published.
- Assuming a marketplace or a supplier handles reporting. Confirm in writing who the producer is for each pack and who is responsible for submission.
- Filing on a calendar you copied from last year. Dates move; use the dated records on this page and recheck near the deadline.
The records show what the published sources say. A decision with real exposure belongs with the regulator or a qualified adviser.
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: report data to the PRO on their supply of covered products in or into the state, and pay membership fees to the PRO
Original wording: Producer Obligations Summary | Resumen de Condiciones y Definiciones
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.866 retrieved
Original wording: the producer of the packaging is the person that manufactures the packaged item
- 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
- 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
- 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.
Original wording: Newspapers USCL 5.0 ¢/lb 0.0 ¢/lb 5.0 ¢/lb
Original wording: Glass Bottles and Jars & Other Containers PRO 10.0 ¢/lb 0.0 ¢/lb 10.0 ¢/lb
Original wording: Aluminum Containers USCL 6.0 ¢/lb 0.0 ¢/lb 6.0 ¢/lb
Original wording: PET (#1) - Bottles, Jugs, and Jars (Clear/ Natural) USCL 25.0 ¢/lb 0.0 ¢/lb 25.0 ¢/lb
Original wording: Wood and Other Organic Materials N/A 105.0 ¢/lb 0.0 ¢/lb 105.0 ¢/lb
- oregon.public.law: ors 459A.926 retrieved
Original wording: At least 25 percent by calendar year 2028 and in each subsequent year
- leginfo.legislature.ca.gov: codes displaySection.xhtml retrieved
Original wording: a producer shall not sell, offer for sale, import, or distribute covered materials in the state unless the producer is approved to participate
Original wording: upon approval of a plan pursuant to Section 42063, or commencing January 1, 2027, whichever is sooner
- calrecycle.ca.gov: packaging epr retrieved
Original wording: SB 54 establishes a new extended producer responsibility (EPR) program to manage packaging and single-use plastic food service ware products
Original wording: Circular Action Alliance has been approved to serve as the first Producer Responsibility Organization.
- calrecycle.ca.gov: producerguidance retrieved
Original wording: PEPRS is CalRecycle’s online portal for: Producer Registration Data Submission Compliance Tracking
Original wording: Circular Action Alliance manages registration, reporting, and submissions of certain exemptions and exclusions on the producers’ behalf.
- calrecycle.ca.gov: exemptionsexclusions retrieved
Original wording: Small producers with gross annual sales of less than $1 million may apply to be exempt from most of the law’s reporting and fee requirements.
- 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: In their most recent fiscal year introduced less than one ton of covered materials
- 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.
- 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.
- cdphe.colorado.gov: producer responsibility program retrieved
Original wording: a producer cannot sell or distribute products that use covered materials in Colorado unless they participate in the Producer Responsibility Program
Original wording: In 2022, Governor Polis signed the Producer Responsibility Program for Statewide Recycling Act into law
Original wording: CDPHE appointed Circular Action Alliance as the designated Producer Responsibility Organization in May 2023.
Original wording: Interchange 360 manages the recycling of automotive lubricant packaging, such as motor oil and antifreeze.
Original wording: All producers of paper products and packaging materials should register with Circular Action Alliance and submit a supply report.
- colorado.public.law: crs 25 17 713 retrieved
Original wording: A person with less than five million dollars in realized gross total revenue, not including on-premises alcohol sales, during the prior calendar year
- colorado.public.law: crs 25 17 709 retrieved
Original wording: no later than January 1, 2026, and annually thereafter by a date determined by the organization
- legislature.maine.gov: title38sec2146 retrieved
Original wording: a producer is exempt from the requirements and prohibitions of this section in any calendar year in which:
Original wording: The department shall administer and enforce this section and shall adopt rules as necessary to implement, administer and enforce this section.
Original wording: The producer realized less than $2,000,000 in total gross revenue during the prior calendar year
- maine.gov: epr retrieved
Original wording: In July 2021, the Legislature passed a law establishing Maine’s Stewardship Program for Packaging, 38 M.R.S. § 2146.
Original wording: Maine DEP to Revise Request for Proposals for Stewardship Organization. (September 11, 2026)
Original wording: Within 90 days of the SO making a registration mechanism available, producers must register with the SO.
Original wording: Producers of packaging material will annually report to the SO by May 31.
- circularactionalliance.org: minnesota retrieved
Original wording: Producers must be a member of a PRO that is registered with MPCA by July 1, 2025.
Original wording: the Minnesota Pollution Control Agency (MPCA) confirmed CAA’s registration to implement the state’s EPR program.
- revisor.mn.gov: 115A.1441 retrieved
Original wording: requirements under sections 115A.144 to 115A.1463
Original wording: introduced less than one ton of covered material into this state
- web.archive.org retrieved
Original wording: the MPCA confirmed Circular Action Alliance (CAA) — a 501(c)(3) nonprofit, producer-led organization — as Minnesota’s initial PRO.
- revisor.mn.gov: 115A.1443 retrieved
Original wording: The producer responsibility organization must register with the commissioner by July 1, 2026, and each January 1 thereafter
- mgaleg.maryland.gov: sb0901E retrieved
Original wording: A PRODUCER MAY NOT SELL, OFFER FOR SALE, DISTRIBUTE, OR IMPORT FOR SALE OR DISTRIBUTION PACKAGING COVERED MATERIALS FOR USE IN THE STATE UNLESS
Original wording: INTRODUCED LESS THAN 1 TON OF COVERED MATERIAL INTO THE STATE
- circularactionalliance.org: maryland retrieved
Original wording: In May 2025, Maryland passed SB 901, an Extended Producer Responsibility
Original wording: Maryland Department of the Environment a list of producers, brands and material type information.
Original wording: serve as the single nonprofit PRO on the State Producer Responsibility Advisory Council
Original wording: Producers must register with CAA by May 31, 2026
- gov.uk: check if you must comply with epr for packaging 2 retrieved
Original wording: you supplied or imported more than 25 tonnes of packaging in the UK in the previous year
- gov.uk (how to comply with packaging recycling obligations as a large producer) retrieved
Original wording: go to schedule 5 of the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (as amended)
- gov.uk: epr for packaging what you must do as a small producer retrieved
Original wording: Each of the 4 nations of the United Kingdom has its own regulator. You’ll be reporting to and monitored by the regulator for your nation.
Original wording: Compliance schemes are third parties that help organisations meet the EPR for packaging requirements.
Original wording: the fee is: £1,303 if you register directly with your environmental regulator £696 if you register through a compliance scheme
- gov.uk (packaging data check reporting periods and submission deadlines) retrieved
Original wording: 1 January to 30 June 2026 1 October 2026
- fostplus.be: become a fost plus member retrieved
Original wording: Does your company put household packaging on the market? Then you have an obligation to report on this packaging to the government.
Original wording: companies that put at least 300 tonnes of single-use packaging on the market annually
- valipac.academy: belgian legislative framework retrieved
Original wording: The new version of the Cooperation Agreement has been in force since 5 March 2020.
Original wording: The Interregional Packaging Commission is responsible for the enforcement of the Cooperation Agreement.
- fostplus.be retrieved
Original wording: This representative must (1) be established in Belgium and (2) be registered with EPRiBEL.
Original wording: Companies that are not members of Fost Plus or another recognised EPR organisation can register directly through EPRiBEL
- fostplus.be: declaration retrieved
Original wording: Exceptionally, you can still amend your 2025 declaration until 15 September this year.
- Oregon 2027: Circular Action Alliance (Oregon PRO) retrieved
Original wording: Wood and Other Organic Materials N/A 0.71 0.00 -0.23 0.48
Original wording: Glass Bottles and Jars & Other Containers PRO 0.04 -0.01 -0.03 0.00
Original wording: Ceramic - All Forms N/A 0.90 0.00 -0.07 0.83
Original wording: HDPE (#2) - Bottles, Jugs and Jars (Clear/Natural) USCL 0.11 0.00 -0.15 -0.04
Original wording: Plastic - Small Format N/A 0.91 0.00 -0.13 0.78
Original wording: PET (#1) - Bottles, Jugs, and Jars (Clear/Natural) USCL 0.28 0.00 -0.09 0.19
Original wording: Aluminum Containers USCL -0.03 0.00 -0.06 -0.09
Original wording: Pressurized cylinders N/A 0.48 0.00 -0.12 0.36
Original wording: Corrugated Cardboard (Tertiary/transport) non- consumer USCL 0.00 0.00 0.00 0.00
Original wording: Other Paper Packaging - Molded Pulp Food Serviceware N/A 0.43 0.00 0.00 0.43
Original wording: Newspapers USCL 0.06 0.00 -0.05 0.01
- Colorado 2027: Circular Action Alliance (Colorado PRO) retrieved
Original wording: Wood and Other Organic Materials N/C $0.84 $0.04 $0.00 $0.00 $0.88
Original wording: PET (#1) - Bottles, Jugs, and Jars (Clear/Natural) MRL $0.19 $0.00 $0.00 -$0.01 $0.18
Original wording: Aluminum Containers MRL $0.05 $0.00 $0.00 $0.00 $0.05
Original wording: Newspapers MRL $0.08 $0.00 $0.00 $0.00 $0.08