Packaging rule · United States · EPR
Oregon Plastic Pollution and Recycling Modernization Act (SB 582)
Extended producer responsibility (EPR) rule covering plastic, paper and board, metal, glass in Oregon, United States, set by Oregon Legislature / Oregon DEQ. Applies since 1 July 2025.
The rule
Recorded from the official source named below. Rates and dates are as the source states them on the date it was consulted.
- Jurisdiction
- United States · Oregon
- Authority
- Oregon Legislature / Oregon DEQ
- Rule type
- EPR
- Materials
- Plastic, Paper and board, Metal, Glass
- Status
- In force Enacted
- Adopted or published
- 1 July 2025
- Applies from
- 1 July 2025
From the source“Oregon's approved PRO CAA was allowed to begin charging fees from member producers on July 1, 2025.”
Official source Oregon DEQ: Producers of Covered ProductsOfficial (government or regulator) · consulted 14 October 2026
Key dates
Adopted or published 1 year and 3 months ago
Applies from 1 year and 3 months ago
Source consulted by the SPI team today
Re-checked by a second SPI team member today
What it means
SPI analysis Our reading of the official source above. Not legal advice; always rely on the official text.
SPI summary
Producers of packaging, paper products and food serviceware must join an approved producer responsibility organization and pay fees that fund recycling system upgrades. Circular Action Alliance is the approved PRO and could charge member fees from 1 July 2025.
In practice
Oregon's Recycling Modernization Act is operating: producers of packaging, paper products and food serviceware sold into Oregon register with Circular Action Alliance (CAA), report in-state supply data and pay membership fees, which CAA could charge from 1 July 2025. Fees are set on reported supply, so the quality of packaging weight and material data directly drives cost. The 25 largest producers by weight also face a life cycle impact evaluation duty, with a first disclosure due on 31 December 2026.
Where the record is unclear
- The numeric small producer threshold is not stated on the DEQ page.
- 2026 fee-cycle deadlines are internal to CAA (DEQ points to page 216 of CAA's plan), so exact dates for later fee years are not on the DEQ page.
- The 31 May 2026 date for 2025 supply data was described by DEQ as an anticipated CAA deadline.
Where it sits in the tracker
- One of 13 packaging rules we track in the United States, of which 7 are EPR rules.
- In all, 25 EPR rules are tracked across 15 jurisdictions. Compare them below
Company profiles that map to this rule
Companies whose SPI profile lists this rule in its regulatory exposure, based on where they report selling. Not company-reported.
Overview
Oregon's Recycling Modernization Act sits in ORS chapter 459A, with producer duties in ORS 459A.869, membership fee rules in ORS 459A.884 and life cycle evaluation in ORS 459A.9441. DEQ's implementing rules are in OAR division 340-090, and Oregon Laws 2021, chapter 681, section 60 allowed the producer responsibility organisation to start charging fees on 1 July 20251. DEQ's summary gives 1 January 2022 as the date the law took effect2.
The law covers three product streams, packaging, printing and writing paper, and food serviceware, and DEQ stresses that whether an item is recyclable does not decide whether it is covered2. DEQ approved Circular Action Alliance's 2025 to 2027 programme plan on 21 February 2025, and that organisation is the only approved PRO in the state1. Fees are set each year by the PRO and reflect the quantity and type of each covered product, environmental factors and each material's effect on system costs2.
Two features go beyond paying for collection. The 25 largest producers by weight must evaluate and publish the life cycle impacts of at least 1% of their covered products every two years, and other producers can run voluntary evaluations to earn ecomodulated fee bonuses3. A private recycling exemption lets producers deduct material that is recycled outside the commingled system, for example tertiary corrugated cardboard, which accounted for 215,872 tons in the pooled 2026 volumes4.
Who must do what
Brand-owning manufacturer of packaged goods
- Register with and join a state-approved PRO, pay its annual membership fee and provide records on request, all from 1 July 20252.
- Report supply data to the PRO; the first 2024 data were due 31 March 2025 under OAR 340-090-0870, and DEQ treats late filers as likely out of compliance1.
- If the brand is licensed to a manufacturer, that licensed manufacturer is the obligated producer instead2.
Importer
- Carry the producer duty where no brand-owning or licensed manufacturer is in the United States2.
First seller of food serviceware into Oregon
- Act as producer of food serviceware, which is usually the manufacturer or a distributor2.
Packer and shipper of remote sales
- Act as producer of the shipping packaging, and notify both the producer of the product sold and that producer's PRO2.
One of the 25 largest producers
- Submit life cycle impact evaluations for the top 1% of covered products by 31 December 2026, or by 30 June 2027 for producers added only on the final March 2026 list (ORS 459A.944(2); OAR 340-090-0910(2)(c))13.
- Post the disclosures on the PRO's website using DEQ's project report and impact assessment templates3.
Are you in scope?
Work through each question. The answers are the SPI team's reading of the sources cited.
Did your company have global gross revenue under $5 million in its most recent fiscal year, or sell under one metric ton of covered products into Oregon?
- If no
- Register with the PRO and report supply data1.
Are you a nonprofit, a public body, a restaurant that does not produce food serviceware, or a single retail store with no online sales and no franchise?
- If no
- Apply the revenue and tonnage tests.
Is the item drug packaging, a Bottle Bill beverage container, a book, a pallet or infant formula packaging?
Is your material collected privately, kept out of commingled processing and recycled at a responsible end market?
- If yes
- You may claim the ORS 459A.869(13) private recycling exemption; DEQ sets the deduction4.
- If no
- Report gross supply and pay on all of it.
Has another party in your supply chain registered as producer for all your covered products sold into Oregon?
- If yes
- You need not join a PRO yourself2.
- If no
- The default producer rules apply.
Compliance checklist
Confirm the producer for each Oregon product
By Now (membership required since 1 July 2025)SPI analysis of the official text. Not legal advice; confirm with the text or counsel. Apply DEQ's rules separately to retail packaging, shipping packaging, food serviceware and printed paper, and record any reassignment to a supply-chain partner2.
Evidence to keep Product list with the producer named and DEQ's decision tree outcome.
Reconcile 2025 supply data
By NowThe PRO used 31 May 2026 as its internal deadline for 2025 data, which sets 2027 fees; DEQ notes this is not a regulatory date1.
Evidence to keep Submitted supply report with weight method.
File the life cycle evaluations if listed
By 31 December 2026Producers on both the August 2025 preliminary list and the March 2026 final list file by this date; those only on the final list have until 30 June 20273.
Evidence to keep Project reports and impact assessment summaries per SKU.
Decide on voluntary evaluations
By Before the PRO's next bonus deadlineBonus A rewards simple evaluation and disclosure; Bonuses B and C reward substantial impact reduction and moves from single-use to refill (OAR 340-090-0910(3))3.
Evidence to keep Evaluation file and bonus application.
Prepare a private recycling claim
By January 2027 windowGather the claim form, the responsible end market self-attestation and documents from every downstream facility up to the end market4.
Evidence to keep Signed forms and chain-of-custody documents.
Follow the third rulemaking
By Early 2027DEQ's third RMA rulemaking runs from September 2025 to early 2027, including requests for new exemptions taken in October 20254.
Evidence to keep Dated note on adopted rule changes.
Enforcement and penalties
- Who enforces
- Oregon Department of Environmental Quality1
- Powers
- DEQ approves the PRO's programme plan, rules on private recycling claims and receives the PRO's list of the 25 largest producers134.
- Enforcement so far
- DEQ states that producers who missed the 31 March 2025 reporting deadline are likely out of compliance; SPI has not identified a published penalty against a producer as of 14 October 20261.
Penalties
| Breach | Penalty | Legal basis |
|---|---|---|
| Failing to register with or join a PRO (a Class 1 violation) | up to $25,000 per day | DEQ civil penalty classification for Recycling Modernization Act producer violations1 |
Non-membership sits in DEQ's most serious violation class, so the cost of ignoring the programme can quickly exceed a year of fees1. SPI has not yet confirmed the specific OAR section that classifies the violation.
How it fits with other rules
- Colorado Producer Responsibility Program for Statewide Recycling (HB22-1355) PR-US-003
Colorado sets its penalties in statute at $5,000 for a first violation plus $1,500 for each continuing day, doubling for a second violation within 12 months (C.R.S. 25-17-710)5. Oregon's Class 1 classification allows up to $25,000 per day for non-membership1. - California SB 54 packaging EPR and permanent regulations PR-US-004
California's small producer exemption is pitched lower, at gross annual sales under $1 million, and is temporary and renewable6. A company exempt in Oregon at $4 million of revenue may still be obligated in California. - Minnesota Packaging Waste and Cost Reduction Act PR-US-006
Minnesota's de minimis line is global gross revenue under $2,000,000 or less than one ton7. Oregon's $5 million line is higher, so mid-sized brands can be exempt in Oregon but in scope in Minnesota2. - Oregon polystyrene foam and PFAS foodware ban (SB 543) PR-US-013
SPI analysis: Oregon's foam and PFAS foodware ban removes some formats from the market altogether, while the remaining food serviceware is a covered product under this Act and carries PRO fees2.
History of the rule
Oregon Laws 2021, chapter 681 enacts the Recycling Modernization Act1.
Law takes effect2.
DEQ approves Circular Action Alliance's 2025 to 2027 programme plan1.
First supply data reports, covering 2024, due to the PRO1.
PRO reports the final list of the 25 largest producers by 2024 weight3.
DEQ sends private recycling determinations, applied to 2027 fee invoices4.
Today
First life cycle evaluations due from listed large producers13.
Life cycle evaluations due from producers added on the final list3.
Questions
Who is Oregon's packaging PRO?
Circular Action Alliance is the only approved PRO. DEQ approved its 2025 to 2027 programme plan on 21 February 2025, and it could charge member fees from 1 July 20251.
What is Oregon's small producer threshold?
A producer with global gross revenue under $5 million in its most recent fiscal year, or under one metric ton of covered products sold into Oregon, is exempt under ORS 459A.863(32). Bottle Bill beverage makers selling under five metric tons of other covered products also qualify2.
What is the life cycle evaluation duty?
Can recycled business-to-business cardboard be deducted?
Yes, through the private recycling exemption in ORS 459A.869(13), if the material is collected privately and recycled at a responsible end market. The pooled 2026 volumes included 215,872 tons of tertiary corrugated cardboard, and the next claim window opens in January 20274.
What happens if a producer does not join the PRO?
DEQ classes failure to register with or join a PRO as a Class 1 violation. Penalties can reach $25,000 per day1.
Definitions
Sources for this analysis
- Oregon DEQ: Producers of Covered Products Regulator · Consulted 14 October 2026
- Oregon DEQ: Producer Obligations Summary, Recycling Modernization Act Regulator · Consulted 14 October 2026
- Oregon DEQ: Life Cycle Impact Evaluation Regulator · Consulted 14 October 2026
- Oregon DEQ: Recycling Modernization Act exemptions Regulator · Consulted 14 October 2026
- Colorado General Assembly: HB22-1355, signed act Official · Consulted 14 October 2026
- CalRecycle: Extensions, Exemptions, and Exclusions Regulator · Consulted 14 October 2026
- Minnesota Statutes: section 115A.1441, Definitions Official · Consulted 14 October 2026
Written by the SPI team on 14 October 2026. Sources checked as of 14 October 2026. SPI analysis, not legal advice; always rely on the official text.
Change history
Verified: a second SPI team member re-checked every fact above against the source on 14 October 2026. Any later change to the facts sends the rule back to Sourced and is logged here.
Verified by a second SPI team member
Changed: rate note
Verified by a second SPI team member
Added to the tracker
Spotted an error? Write to sales@strategicpackaginginsights.com quoting PR-US-002 and the source. Corrections are logged in this history.
EPR rules elsewhere
The same type of rule for the same materials in other jurisdictions, by the date it applies.
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