Washington's recycling needs assessment closes for comment on 30 October. Its cost data will set reimbursement from 50% in 2030

How Washington's needs assessments work

The Recycling Reform Act is SB 5284 of 2025, titled “Improving Washington’s solid waste management outcomes”. The Legislature’s bill summary shows it was signed on 17 May 2025 as Chapter 316, Laws of 2025, and took effect on 27 July 2025⁸. It created Chapter 70A.208 RCW, tracked by SPI as PR-US-008.

The law runs on two assessments. RCW 70A.208.110 requires a preliminary needs assessment by 31 December 2026 and a full statewide needs assessment by 31 December 2027, repeated every five years⁵. Ecology must hire a third party to do the work, and that contractor cannot be a producer, a PRO or a member of the advisory council.

The preliminary assessment is a snapshot. It covers a period of 12 to 36 months and must report covered materials introduced, tons collected, current services and costs in each county and city, and gaps such as areas with curbside garbage but no curbside recycling. It must also record the capacity of material recovery facilities (MRFs), compost sites, drop-off sites and transfer stations, plus in-state markets.

The full assessment goes further. It must propose five-year outcome ranges for source reduction, reuse, recycling, composting and recycled content, and recommend a methodology for setting reimbursement rates under RCW 70A.208.170. The statute says a needs assessment is the baseline for judging whether performance targets have been met.

The assessments sit inside a longer sequence. Producers had to appoint a PRO by 1 January 2026 and be members of a registered PRO from 1 July 2026, under RCW 70A.208.030 and .040. Ecology is writing implementing rules in chapter 173-950 WAC, and RCW 70A.208.060 says approval of the first plans, due on 1 October 2028, takes effect no earlier than the adjournment of the 2029 regular legislative session.

“We invite you to comment on the Preliminary Needs Assessment” Washington Department of Ecology, needs-assessments page, October 2026

What changed in October

1 October: initial collection lists due. RCW 70A.208.060 set 1 October 2026 for Ecology to develop initial statewide collection lists, which RCW 70A.208.090 describes as lists “for use and evaluation in the needs assessment”⁷. Ecology’s 15 July blog had scheduled statewide standardised collection lists for October 2026, after public comment in August. SPI has not yet confirmed the final form in which the lists were published.

1 October: the draft is released. Ecology’s needs-assessments page opened a comment period running from 1 to 30 October 2026 and links the draft document, whose file name carries the date 1 October 2026¹. The page says the draft examines recycling access compared with garbage and organics collection, recycling costs, tonnes disposed, recycled and composted, potential for more recovery, and end markets.

The 90-day rule. RCW 70A.208.110 requires the draft to be available for comment at least 90 days before the assessment is finalised. From 1 October to 31 December 2026 is 91 days, by SPI’s calculation, so the release met the floor with one day to spare. Ecology must respond in writing to comments from the advisory council and from PROs.

15 October: the carton industry responds. The Carton Council, whose members are Elopak, Novolex, SIG and Tetra Pak, filed a letter on the comment portal disputing the draft’s carton figures¹⁰. It cites Tables 13 and 14 of the 1 October draft and asks the contractor to revise its estimates.

19 October: a resident’s comment. A Seattle resident’s comment, the second on the public comment list, praised the draft’s candour about data gaps and asked for mandatory, consistent reporting by service providers⁹. It cites a draft cost figure of about USD 432 per ton, which it says the draft labels low confidence, and only five statewide facilities accepting certified compostable packaging. SPI has not yet confirmed either figure in the draft itself.

Next: final text by 31 December. The final preliminary assessment is due by 31 December 2026 under statute. Ecology’s July blog placed the preliminary needs assessment in January 2027, which may refer to publication, and SPI has not yet confirmed whether Ecology expects to publish the final text before or after the new year.

“incorporate relevant cost information identified by the needs assessment” RCW 70A.208.170, on how reimbursement rates must be set

What the statute requires of the two assessments

The two assessments are written into the statute item by item, and the second one shapes the money. The table sets out what RCW 70A.208.110 requires and what each item means for producers and service providers.

The reimbursement rule is the line producers will watch. RCW 70A.208.170 requires rates based on net costs for covered services, after estimated revenue from selling the material, using relevant material indices⁶. Costs counted include collection, transfer, sorting and processing, contamination management, administration and reuse or refill.

The floors rise in three steps: “No less than 50 percent of the net costs by February 15, 2030”, 75% by 15 February 2031 and 90% by 15 February 2032 and each year after. Rates must be updated annually. RCW 70A.208.040 separately requires the PRO to reimburse service providers at intervals no longer than monthly unless both sides agree otherwise.

Ecology’s programme page words the schedule differently, saying the PRO will reimburse at least 90% from 2030³. The statute’s floor is 50% in 2030, and Ecology’s July blog says household bills fall by at least 90% after 2032, “when the program reimbursement rate reaches the highest level”. SPI follows the statutory schedule.

The plan stage has its own clock. Under RCW 70A.208.060, Ecology must act on a draft plan within 120 days of receipt, after a public comment period of at least 45 days, and a PRO has 60 days to supply more information or revise after a denial⁷. The assessment figures settled in December 2026 and December 2027 are therefore the numbers Ecology will test the 2028 plan against.

Data access is built in. Service providers and others must supply requested data, may ask for confidential treatment under RCW 70A.208.220, and the contractor must aggregate and anonymise nonpublic data before it appears in the assessment. Ecology’s April 2026 request for information, publication 26-07-021, sought that input with responses due on 8 May 2026¹¹.

The same request confirmed the order of work. Ecology said the preliminary needs assessment is due by 31 December 2026, and it asked service providers, local governments and others for data on collection, processing and costs to feed both the collection lists and the assessments.

Who gains and who pays as the baseline is set

Carton makers: Elopak, Novolex, SIG and Tetra Pak. The Carton Council’s members have the most direct stake in the figures already disputed. Its letter says the draft’s Table 13 shows 7,451 tons of aseptic cartons and 12,882 tons of gable-top cartons generated at Washington residences in 2024, and Table 14 adds 939 tons from self-haulers, for 21,272 tons in all. Higher tonnage can mean a larger share of system cost, which is why the Council asks for a downward revision.

Recycling rates by format. On the same figures, 34.9% of aseptic cartons and 49.0% of gable-top cartons were recycled, by SPI’s calculation. The Council says Oregon DEQ’s residue correction would cut carton weights by about 25%, because field samples carry food and drink residue.

The national yardstick. The Council also cites The Recycling Partnership’s 2026 estimate of 598,835 tons of cartons nationally, or 4.0 pounds per person a year, and says that national figure is about 25% less than the consultant’s current estimate for Washington. It offers to meet the consultant team to discuss its estimating method.

Circular Action Alliance. CAA was announced as Washington’s PRO on 4 March 2026 and must pay at least 50% of net costs from February 2030. Ecology’s July blog says producers must join CAA and that fees depend on the volume of packaging introduced, with lower fees for recyclable materials⁴.

Interchange360. Ecology’s blog says Interchange360 has registered to run an alternative collection programme for automotive lubricant packaging, a separate route from the main CAA plan.

Cities, counties and haulers. Service providers gain once reimbursement starts, but the rate depends on the costs the assessment records. A resident’s comment cites a draft cost figure of about USD 432 per ton labelled low confidence; SPI has not yet confirmed it in the draft. Households pay about USD 8 to 10 a month for curbside recycling today, Ecology’s blog says.

Glass and PET. The same resident’s comment cites draft figures of about 43% of PET bottles and 35% of glass bottles found in garbage, and one in-state glass end market since the 2024 Ardagh closure. SPI has not yet confirmed these in the draft.

Ecology’s July blog puts the wider stakes in numbers drawn from earlier studies. Curbside recycling would expand from 2.8 million households, 83% of residents, to 3.2 million, over 95%, and residential recovery would rise from about 40% to an expected 66%⁴. The blog also cites about 565,000 fewer metric tons of greenhouse gas emissions a year.

The data problem behind the reimbursement rate

The assessment is only as good as the data service providers send. Ecology’s April request for information sought input on collection lists and needs assessments, and a resident’s comment says it drew 30 responses statewide, a figure SPI has not yet confirmed. The same comment says the draft’s cost figure rests on about 100 usable data points.

The carton dispute shows how extrapolation shapes results. The Carton Council understands the draft scales 15 regional waste composition studies from 2020 to 2025 up to the state, and it argues that method or the field data overstates cartons. It asks Ecology to weigh new Washington composition studies due in the coming year in the full assessment due in 2027.

Timing matters as much as accuracy. The preliminary assessment is due on 31 December 2026, but the reimbursement methodology is recommended in the full assessment a year later, and the PRO plan follows on 1 October 2028. Errors in tonnage or cost can therefore be corrected before rates are set, if comments land now.

Measurement rules raise a second issue. The resident’s comment says the draft’s Table 13 counts material as recycled when it enters the recycling cart, even if it is later landfilled, and asks Ecology to track material through processing to end markets. SPI has not yet confirmed how the draft defines recycled tonnage, but the full assessment must evaluate contamination levels, causes and management costs under RCW 70A.208.110.

How Washington compares with Minnesota, Colorado, Oregon and California

Five states run packaging EPR with CAA as the PRO, but they sit at different points of the needs-assessment and reimbursement cycle. Minnesota is the closest match: its statute also phases reimbursement from 50% to 90%, and its draft 2026 needs assessment is open for comment until 13 November 2026, MPCA’s programme page says¹⁵.

Minnesota moves a year ahead of Washington. Its preliminary assessment was due on 31 December 2025 and its first full one on 31 December 2026, and section 115A.1455 sets reimbursement of at least 50% of net costs from 1 February 2029, 75% in 2030 and 90% from 2031¹⁶. Its stewardship plan is due on 1 October 2028, the same day as Washington’s.

Colorado has finished the stage Washington is starting. CDPHE’s programme page says the Joint Budget Committee chose the medium needs-assessment scenario in March 2024, and the executive director approved the programme plan in December 2025¹⁷. Colorado’s plan must reimburse 100% of service providers’ net recycling costs, with first dues payable from January 2026. The Act also requires the programme to extend to nonresidential entities by 2028 at the latest, and to meet collection, recycling and recycled content targets by 1 January 2030 and 1 January 2035.

Oregon and California fit the comparison less neatly. SPI’s tracker records for Oregon (PR-US-002) and California (PR-US-004) do not set out a needs-assessment stage or a reimbursement percentage schedule, and SPI has not yet confirmed either from official sources. Oregon’s CAA plan for 2025 to 2027 was approved on 21 February 2025, and in California CAA submitted its plan to the Advisory Board on 15 June 2026. California’s targets are written as outcomes rather than reimbursement shares: by 1 January 2032, single-use plastic must be cut by 25% and recycled at 65%, and plastic producers fund a USD 500 million a year mitigation fund for ten years from July 2027.