Oregon EPR do I have to register
Last verified
Under the rules we hold, Oregon has a packaging EPR obligation, and the producer is the manufacturer or brand owner, licensee, or importer. The size limit on record is $5,000,000, so small producers may fall below it. The answer depends first on whose brand is on the packaging.
Check your own case
Choose your role, add your revenue and the packaging you supply, and the checker applies the rules this page describes to your figures. It runs in your browser and stores nothing.
Preliminary. This is what the encoded rules indicate for your answers, not legal advice. You check it, then sign and submit yourself.
The Instica free plan covers the threshold check, exemption tracking, the deadline calendar, packaging templates and fee sources, so you can start without paying. See what the free plan includes
How the checker reaches a result
The checker asks the same questions in the same order for every place, and it stops with a result as soon as a question settles the matter. It never fills a missing answer in for you.
- Whose brand is on the packaging? If it is another company's brand, you are not the producer for those goods under the roles recorded for Oregon. If you have not said, the checker asks first.
- Do you sell into Oregon? A place where you report no sales returns not obligated.
- Does a size limit apply? The checker compares your revenue or packaging weight with each limit on record and, where a limit is not met, returns below threshold.
- Is an exemption on record for your case? An exemption that is not yet verified is never assumed, and the checker asks for more data instead.
- Are related companies counted together? Where the rules add up affiliated companies, their figures are combined before the limits are compared.
Who is the producer in Oregon?
The first question is whose duty it is. Oregon assigns the duty by packaging level, and the table shows which roles count as the producer at each level.
| Packaging level | Producer |
|---|---|
| other packaging | first distributor |
| primary (sales) packaging | manufacturer or brand owner, licensee, or importer |
| secondary packaging | manufacturer or brand owner, licensee, or importer |
| service packaging | first distributor |
| shipping packaging | packer or shipper |
| tertiary (transport) packaging | first distributor |
- Oregon: for other packaging the producer is the first distributor.
- Oregon: for primary (sales) packaging the producer is the manufacturer or brand owner, licensee, or importer.
- Oregon: for secondary packaging the producer is the manufacturer or brand owner, licensee, or importer.
- Oregon: for service packaging the producer is the first distributor.
- Oregon: for shipping packaging the producer is the packer or shipper.
- Oregon: for tertiary (transport) packaging the producer is the first distributor.
Find the row that describes you. Where more than one role appears in a row, the checker asks whose brand is on the product before it gives a result.
Does revenue matter in Oregon?
Where a revenue limit applies, Oregon counts gross revenue of the organisation. The revenue figure is taken over the fiscal year. Limits are stated in USD; a figure in another currency is converted with a published rate before it is compared.
Size limits in Oregon
Some rules switch the duty on or off by size. These are the limits on record for Oregon, each with what happens when you meet it.
The revenue limit: $5,000,000
Oregon: the revenue limit is $5,000,000. Oregon: at the revenue limit of $5,000,000, the producer is exempt below it. Oregon: the revenue limit of $5,000,000 applies to figures below it. Oregon: the revenue limit is counted as follows: 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: oregon.public.law: ors 459A.863
The tonnage limit: 1 metric ton
Oregon: the tonnage limit is 1 metric ton. Oregon: at the tonnage limit of 1 metric ton, the producer is exempt below it. Oregon: the tonnage limit of 1 metric ton applies to figures below it. Oregon: the tonnage limit is counted as follows: 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: oregon.public.law: ors 459A.863
The tonnage limit: 5 metric tons
Oregon: the tonnage limit is 5 metric tons. Oregon: at the tonnage limit of 5 metric tons, the producer is exempt below it. Oregon: the tonnage limit of 5 metric tons applies to figures below it. Oregon: the tonnage limit is counted as follows: covered products, including secondary and tertiary packaging for beverage containers, most recent calendar year.
The revenue limit: $10,000,000
Oregon: the revenue limit is $10,000,000. Oregon: at the revenue limit of $10,000,000, a flat-fee band applies. Oregon: the revenue limit of $10,000,000 applies to figures below it. Oregon: the revenue limit is counted as follows: gross revenue, most recent fiscal year, or under 5 metric tons sold in or into Oregon.
Exemptions in Oregon
An exemption removes the duty for a producer that meets its conditions. Some must be applied for; others apply on their own.
Exemption 1
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. Oregon: exemption 1 applies without an application. Oregon: exemption 1 is renewed as follows: Status is tested each year against the most recent fiscal or calendar year. DEQ recommends producers near a threshold still register and report.
Exemption 2
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. Oregon: exemption 2 applies without an application.
Exemption 3
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. Oregon: exemption 3 must be applied for. Oregon: the application window for exemption 3 is: 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. Oregon: exemption 3 is renewed as follows: annual claim.
What the rules cover in Oregon
A duty applies only to the packaging and the sales channels that the rules cover. This is what is on record for Oregon.
Oregon: the rules cover these sales channels: physical retail, remote sales, and other distribution. Oregon: a producer may pass the duty to another party under the rules.
Every case, worked through
Below, the same engine that powers the checker is run on a set of standard cases for Oregon. Each case states the input, the result and the next step. The figures are test inputs set at half, equal to and twice each recorded limit, read as of September 29, 2026; they are not rules.
Revenue of $2,500,000: below the limit
Your own brand is on the goods and your revenue is $2,500,000, half the limit of $5,000,000. The figure is under the $5,000,000 limit, so the engine returns below threshold: the exemption on record applies. Result: below threshold. Next: keep the figures that put you below the limit, and check again as you grow.
Revenue of $5,000,000: exactly at the limit
Your own brand is on the goods and your revenue is $5,000,000, exactly the limit of $5,000,000. The rules for Oregon set a limit that needs a figure this case does not supply, such as a different measure or unit, so the engine asks for more data. Result: more data needed. Next: supply the missing answer in the checker to get a result.
Revenue of $10,000,000: above the limit
Your own brand is on the goods and your revenue is $10,000,000, twice the limit of $5,000,000. The rules for Oregon set a limit that needs a figure this case does not supply, such as a different measure or unit, so the engine asks for more data. Result: more data needed. Next: supply the missing answer in the checker to get a result.
Packaging of 0.5 metric tons: below the limit
Your own brand is on the goods and you supply 0.5 metric tons of packaging, half the limit of 1 metric ton. The figure is under the 1 metric ton limit, so the engine returns below threshold: the exemption on record applies. Result: below threshold. Next: keep the figures that put you below the limit, and check again as you grow.
Packaging of 2 metric tons: above the limit
Your own brand is on the goods and you supply 2 metric tons of packaging, twice the limit of 1 metric ton. The rules for Oregon set a limit that needs a figure this case does not supply, such as a different measure or unit, so the engine asks for more data. Result: more data needed. Next: supply the missing answer in the checker to get a result.
Packaging of 2.5 metric tons: below the limit
Your own brand is on the goods and you supply 2.5 metric tons of packaging, half the limit of 5 metric tons. The rules for Oregon set a limit that needs a figure this case does not supply, such as a different measure or unit, so the engine asks for more data. Result: more data needed. Next: supply the missing answer in the checker to get a result.
Packaging of 10 metric tons: above the limit
Your own brand is on the goods and you supply 10 metric tons of packaging, twice the limit of 5 metric tons. The rules for Oregon set a limit that needs a figure this case does not supply, such as a different measure or unit, so the engine asks for more data. Result: more data needed. Next: supply the missing answer in the checker to get a result.
Revenue of $5,000,000: below the limit
Your own brand is on the goods and your revenue is $5,000,000, half the limit of $10,000,000. The rules for Oregon set a limit that needs a figure this case does not supply, such as a different measure or unit, so the engine asks for more data. Result: more data needed. Next: supply the missing answer in the checker to get a result.
Revenue of $10,000,000: exactly at the limit
Your own brand is on the goods and your revenue is $10,000,000, exactly the limit of $10,000,000. The rules for Oregon set a limit that needs a figure this case does not supply, such as a different measure or unit, so the engine asks for more data. Result: more data needed. Next: supply the missing answer in the checker to get a result.
Revenue of $20,000,000: above the limit
Your own brand is on the goods and your revenue is $20,000,000, twice the limit of $10,000,000. The rules for Oregon set a limit that needs a figure this case does not supply, such as a different measure or unit, so the engine asks for more data. Result: more data needed. Next: supply the missing answer in the checker to get a result.
Above every limit
Your own brand is on the goods and every figure is above every limit on record. The limit is met, so the engine returns obligated. Result: obligated. Next: register, report and pay as the sections below describe, and prepare your figures in a workspace.
If you owe: what happens next
If the result is obligated, these are the steps on record for Oregon. You register, report and pay yourself; Instica prepares the figures and the files.
Oregon: registration is made with Circular Action Alliance producer portal (PRO registration); DEQ holds no separate producer registry. Oregon: registration is made by this party: The producer, with the PRO, after signing the Producer Participant Agreement and the Oregon addendum.
Oregon: producers meet the duty through a single producer responsibility organisation. Oregon: the organisations on record are Circular Action Alliance. Oregon: membership of an organisation is required. Oregon: an authorised representative is not required.
Deadlines on record
- Oregon: the reporting deadline is May 31, 2026.
- Oregon: the other deadline is July 1, 2025.
- Oregon: the other deadline is January 1, 2027.
- Oregon: the reporting deadline is December 31, 2026.
Flat fees on record
- Oregon: for packaging of 1 to 2.5 tonnes, the 2026 flat fee is $1,200.00.
- Oregon: for packaging of 2.5 to 5 tonnes, the 2026 flat fee is $2,500.00.
- Oregon: for packaging of 5 to 7.5 tonnes, the 2026 flat fee is $4,100.00.
- Oregon: for packaging of 7.5 to 10 tonnes, the 2026 flat fee is $5,800.00.
- Oregon: for packaging of 1 to 2.5 tonnes, the 2027 flat fee is $700.00.
- Oregon: for packaging of 2.5 to 5 tonnes, the 2027 flat fee is $1,300.00.
- Oregon: for packaging of 5 to 7.5 tonnes, the 2027 flat fee is $2,200.00.
- Oregon: for packaging of 7.5 to 10 tonnes, the 2027 flat fee is $3,100.00.
Frequently asked questions
Do I owe packaging EPR in Oregon?
Under the rules we hold, Oregon has a packaging EPR obligation, and the producer is the manufacturer or brand owner, licensee, or importer. The size limit on record is $5,000,000, so small producers may fall below it. The answer depends first on whose brand is on the packaging.
Who is the producer in Oregon?
At the primary packaging level the producer is the manufacturer or brand owner, licensee, or importer. The table above lists the other levels.
Is there a size limit in Oregon?
Yes. The limit on record is $5,000,000; below it the rules treat you differently, as the cases above show.
Do I have to join a producer responsibility organisation in Oregon?
Membership of an organisation is required. The organisations on record: Circular Action Alliance.
Will Instica register or file for me in Oregon?
No. Instica measures, estimates and prepares your figures and files. You register, sign and submit each filing yourself, and Instica never stores portal credentials.
Is this legal advice?
No. This page is information about published rules and an estimate from them, not legal advice. Check the sources named beside each figure before you act.
Which states have passed EPR laws?
Oregon: the rules cover these sales channels: physical retail, remote sales, and other distribution. Oregon: a producer may pass the duty to another party under the rules.
Do I have to register my trailer in Oregon?
Oregon: registration is made with Circular Action Alliance producer portal (PRO registration); DEQ holds no separate producer registry. Oregon: registration is made by this party: The producer, with the PRO, after signing the Producer Participant Agreement and the Oregon addendum.
What is EPR registered?
Oregon: producers meet the duty through a single producer responsibility organisation. Oregon: the organisations on record are Circular Action Alliance.
What are the new recycling rules in Oregon?
Oregon: a packaging EPR obligation applies. Oregon: for other packaging the producer is the first distributor.
How to read these figures
Every figure in the app carries a data-quality label: measured, supplier, estimated or declared. How we measure and label figures. This page is information, not legal advice.
Sources
- 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
Original wording: "Covered product" means: (A) Packaging; (B) Printing and writing paper; and (C) Food serviceware.
- 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.
- oregon.gov: producers of covered products retrieved
Original wording: In order to access CAA's data reporting portal, producers must first sign the Producer Participant Agreement with CAA
Original wording: Circular Action Alliance, at present, is Oregon's only approved Producer Responsibility Organization
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
- 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: 1 2.5* $1,200
Original wording: Metric Ton 2.5 5* $2,500
Original wording: 5 7. 5 $4,100
Original wording: 7. 5 10 $5,800
- circularactionalliance.org: OR 2027FeeSchedule 100126 retrieved
Original wording: 1 2.5* $700
Original wording: 2.5 5* $1,300
Original wording: 5 7.5 $2,200
Original wording: 7.5 10 $3,100
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