From 2025 onward, producers of products covered under Oregon's Recycling Modernization Act (packaging, paper, and food serviceware) 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, at present, 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. CAA is also 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
The first compliance deadline for producers to report their supply of covered products in or into the state to Circular Action Alliance has passed: reporting of 2024 supply data was required of all obligated producers on or before March 31, 2025, pursuant to OAR 340-090-0870.
The subsequent cadence of supply reporting is internal to CAA, enabling CAA to compile its required annual report of producer supply data to DEQ, pursuant to ORS 459A.887(2)(c), due each year on June 30. The supply reporting deadlines must also enable CAA to input data from two years prior into fee-setting for a given program year as required pursuant to OAR 340-090-0700(4)(b).
Beginning with May 31, 2026, supply data for the prior year are due to CAA on or before May 31 of each year.
Producers who have not yet reported 2024 or 2025 supply data to CAA are likely out of compliance and are encouraged to do so immediately.
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.
Pursuant to 2021 c.681 §60, Oregon's approved PRO CAA was allowed to begin charging fees from member producers on July 1, 2025. Fees charged by the PRO must meet statutory requirements laid out at ORS 459A.884 and the PRO must follow the approach laid out in its program plan. Deadlines for fee payment are internal to CAA, sequenced in order to enable CAA to implement its program as described in its program plan.
Producers who have not yet paid 2025 or 2026 fees to CAA are likely out of compliance and are encouraged to follow up with CAA immediately.
See pg 216 of CAA's approved program plan, where a timeline including the 2026 fee-setting process is represented.
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.
Each year, DEQ will open a claim submission window for this exemption during the first quarter of the year. Producers will submit data from the previous year to support claims for exemptions to apply toward the next year's fees.
See DEQ's Recycling and Modernization Act Exemptions page for more information.
The window for exemption claims for the 2027 fee year is open Jan. 6, 2026, through until March 31, 2026, at 5 p.m. PT.
Pursuant to ORS 459A.944(2) and OAR 340-090-0910(2)(c), the top 25 producers by market share must submit their first batch of required life cycle impact evaluations at the end of 2026. See the list of top 25 producers and information about this requirement on DEQ's life cycle evaluation web page.
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