Beginning in 2025, producers of covered products (packaging, paper, and food serviceware) under Oregon's Recycling Modernization Act must, pursuant to ORS 459A.869(1) and (5), register with an approved Producer Responsibility Organization, report data to the PRO on their supply of covered products in or into the state, and pay membership fees to the PRO. The 25 largest producers in the state by weight of covered product have an additional obligation to conduct and disclose life cycle impact evaluation on 1% of their covered products on a biennial basis, pursuant to ORS 459A.944(2).
Note: small producers as defined at ORS 459A.863(32) are exempt from the producer obligations under the Act.
Oregon's PRO
Circular Action Alliance is Oregon's only approved Producer Responsibility Organization, having received approval from Oregon DEQ on Feb. 21, 2025, of its program plan for 2025-2027. DEQ strongly encourages all potentially-obligated producers to register with CAA via its website and visit the Producer Resource Center for additional details and answers to some frequently asked questions. Additionally, CAA is your first point of contact for reporting guidance and other inquiries regarding producer obligations: such inquiries can be submitted to CAA's Producer Services team at Producer.Support@circularaction.org.
Key deadlines
Claim submission deadline of March 28, 2025, for the private recycling exemption for the 2025 and 2026 fee years
Pursuant to ORS 459A.869(13), producers may demonstrate to the department that a portion of their material is eligible for exemption because it is recycled responsibly outside of the commingled recycling system. See
DEQ's Recycling and Modernization Act Exemptions page for more information.
Pre-registration (Reporting) deadline of March 31, 2025
Pursuant to OAR 340-090-0870, producers must report 2024 supply data of covered products in or into Oregon to CAA by March 31, 2025. This data is vital to all CAA to set fair and accurate producer fees for the 2025 and 2025 program years that producers begin to pay on July 1, 2025.
- In order to access CAA's data reporting portal, producers must first sign the Producer Participant Agreement with CAA and the Oregon-specific addendum.
- In order to file the report, a producer will need to
- identify the covered products in its supply chain,
- determine whether or not it is the obligated producer for the covered products, and
- determine and apply the appropriate supply reporting methodology.
CAA has guidance documents specific to each of these three elements available for registered producers. Additional resources listed at the bottom of this page may also be helpful.
- Because fee rates are allocated based on producer supply, it is critical that all producers report their material supply data to CAA on time each year. Fee rates will change annually.
Registration (Fee Payment) Start Date of July 1, 2025
Pursuant to 2021 c.681 §60, the PRO may begin charging fees from member producers on July 1, 2025. Invoices may be sent prior to that date.
Large producer first impact disclosure date of Dec. 31, 2026
Pursuant to OAR 340-090-0910(2)(c), the top 25 producers must submit their first batch of required life cycle impact evaluations at the end of 2026.
Enforcement
Failing to register or become a member of a producer responsibility organization is a Class 1 violation that can result in fines of up to $25,000 per day.
Resources on DEQ’s enforcement process