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

Comments on Washington Ecology’s draft preliminary needs assessment close on 30 October 2026, and its cost data will feed producer-funded reimbursement of at least 50% of net recycling costs by February 2030, rising to 90% by 2032.

By the SPI teamPublished 14 min read

The statute lifts the PRO's reimbursement floor from 50% of net costs in 2030 to 90% in 2032, priced on needs-assessment cost data Unit: % of service providers' net costs, minimum
The statute lifts the PRO's reimbursement floor from 50% of net costs in 2030 to 90% in 2032, priced on needs-assessment cost data3 bars. Largest: 15 Feb 2032 onwards, 90.15 Feb 2032 onwards15 Feb 2032 onwards: 90 % of service providers' net costs, minimum9015 Feb 203115 Feb 2031: 75 % of service providers' net costs, minimum7515 Feb 203015 Feb 2030: 50 % of service providers' net costs, minimum50The statute lifts the PRO's reimbursement floor from 50% of net costs in 2030 to 90% in 2032, priced on needs-assessment cost data3 bars. Largest: 15 Feb 2032 onwards, 90.15 Feb 2032 onwards15 Feb 2032 onwards: 90 % of service providers' net costs, minimum9015 Feb 203115 Feb 2031: 75 % of service providers' net costs, minimum7515 Feb 203015 Feb 2030: 50 % of service providers' net costs, minimum50

Source: RCW 70A.208.170(2)(a), consulted, checked 31 Oct 2026.

Statutory minimums. Ecology's programme page says the PRO will reimburse at least 90% starting in 2030; the statute phases the floor in over three years.

Show the data
The statute lifts the PRO's reimbursement floor from 50% of net costs in 2030 to 90% in 2032, priced on needs-assessment cost data (% of service providers' net costs, minimum)
DateMinimum share (% of service providers' net costs, minimum)
15 Feb 2032 onwards90
15 Feb 203175
15 Feb 203050

Key takeaways

  • Ecology’s needs-assessments page says the comment period on the draft preliminary needs assessment runs from 1 to 30 October 2026, with comments taken online.
  • RCW 70A.208.110 requires the final preliminary needs assessment by 31 December 2026 and the first full needs assessment by 31 December 2027, then every five years.
  • RCW 70A.208.170 sets reimbursement of at least 50% of net costs by 15 February 2030, 75% by 15 February 2031 and 90% by 15 February 2032.
  • The Carton Council’s comment of 15 October 2026 says the draft’s carton generation estimates are higher than actual quantities and asks for them to be revised.
  • SPI analysis: Minnesota’s draft 2026 needs assessment takes comments to 13 November 2026, so producers active in both states face two cost baselines in the same month.
Comments close on 30 October, the final preliminary assessment is due on 31 December, and reimbursement must reach 90% of net costs by February 2032

30

Comment period on the draft

days, 1 to 30 October 2026

Ecology, Needs assessments page

31 Dec 2026

Final preliminary needs assessment due

statutory deadline

RCW 70A.208.110

90

Reimbursement floor from 15 Feb 2032

% of service providers' net costs

RCW 70A.208.170

Source: Ecology, Needs assessments page, consulted 20 Oct 2026; RCW 70A.208.110 and 70A.208.170, checked 31 Oct 2026.

The Washington Department of Ecology’s draft preliminary needs assessment, dated 1 October 2026, takes public comment until 30 October, and the final version is due by 31 December 2026 under the 2025 Recycling Reform Act.

The assessment is the first statewide baseline of who has recycling, what it costs and where material goes under Chapter 70A.208 RCW, Washington’s packaging extended producer responsibility (EPR) law, which makes producers pay for residential recycling. The statute tells the producer responsibility organisation (PRO) to build its reimbursement rates on “relevant cost information identified by the needs assessment”.

For a board or a buyer, that link is why ten days of comment matter. Circular Action Alliance (CAA) must reimburse at least 50% of service providers’ net costs by 15 February 2030 and 90% by 15 February 2032, and producer fees will be set to fund those payments. Two comments were public on Ecology’s portal by 19 October, one of them from the carton industry disputing the draft’s tonnage.

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.

The Carton Council says the draft puts 2024 residential carton generation at 20,333 tons, with gable-top cartons recycled at a higher rate than aseptic Unit: tons, 2024, residential
The Carton Council says the draft puts 2024 residential carton generation at 20,333 tons, with gable-top cartons recycled at a higher rate than aseptic2 bars. Largest: Gable-top, 12,882.Gable-topGable-top: 12,882 tons, 2024, residential12,882AsepticAseptic: 7,451 tons, 2024, residential7,451The Carton Council says the draft puts 2024 residential carton generation at 20,333 tons, with gable-top cartons recycled at a higher rate than aseptic2 bars. Largest: Gable-top, 12,882.Gable-topGable-top: 12,882 tons, 2024, residential12,882AsepticAseptic: 7,451 tons, 2024, residential7,451

Source: Carton Council comment letter, 15 Oct 2026, citing Table 13 of Ecology's draft of, checked 31 Oct 2026.

Figures as quoted by the Carton Council. SPI has not yet confirmed them in the draft. Totals are SPI's calculation.

Show the data
The Carton Council says the draft puts 2024 residential carton generation at 20,333 tons, with gable-top cartons recycled at a higher rate than aseptic (tons, 2024, residential)
Carton typeGeneratedDisposedRecycledOrganics
Gable-top12,8825,9596,317605
Aseptic7,4514,7372,604109

“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 preliminary assessment records today's system, and the full assessment in 2027 must recommend how reimbursement rates are set
RequirementStatuteWhat it means
Preliminary needs assessment completeRCW 70A.208.110; 70A.208.060(2)(g)Due 31 Dec 2026, covering 12 to 36 months of data
Draft open to comment at least 90 days before finalRCW 70A.208.110Draft of 1 Oct 2026 meets the floor for a 31 Dec final
Services and costs by county and cityRCW 70A.208.110Sets the cost base reimbursement draws on
MRF, compost, drop-off and transfer capacityRCW 70A.208.110Shows where investment is needed
Estimated total annual collection and processing costRCW 70A.208.110Based on registered service provider costs
Volume, weight and types introduced by producersRCW 70A.208.110Links tonnage to the fee base
Full needs assessment completeRCW 70A.208.110; 70A.208.060(2)(i)Due 31 Dec 2027, then every five years
Recommended reimbursement rate methodologyRCW 70A.208.110Feeds the PRO plan due 1 Oct 2028
Five-year outcome ranges by materialRCW 70A.208.110Basis for performance targets
Reimbursement methodology uses needs-assessment costsRCW 70A.208.170Rates updated annually, net of material sale revenue

Source: RCW 70A.208.110, 70A.208.060 and 70A.208.170, consulted, checked 31 Oct 2026.

Summary of statutory requirements. Not legal advice; check the text or counsel.

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.

Industry reaction

“These generation estimates are higher than what the Carton Council believes to be the actual quantity”

Carton Council, carton manufacturers’ coalition, comment letter on the draft preliminary needs assessment, 15 October 2026

The letter puts 2024 carton generation at 5.29 pounds per person from the draft’s tables and compares it with 2.31 pounds per person in Oregon DEQ’s residue-corrected 2023 data.

“We are honored to be implementing Washington’s program”

Circular Action Alliance, chief executive, release on its appointment as Washington’s PRO, 4 March 2026

CAA’s release said its role is to help producers meet their obligations under the law; as the PRO it will pay the reimbursements the needs assessment helps price.

“Starting in 2030, the PRO will reimburse at least 90% of the recycling system cost to service providers who collect and process residential packaging and paper products.”

Washington Department of Ecology, state regulator, Recycling Reform Act programme page, consulted 20 October 2026

The statement sits beside RCW 70A.208.170, whose floor is 50% by 15 February 2030 and 90% only from 15 February 2032.

“This landmark law marks another major victory for producer responsibility in the U.S.”

Product Stewardship Institute, chief executive, statement on the signing of SB 5284, 23 May 2025

The Product Stewardship Institute’s statement came six days after the Governor signed the bill on 17 May 2025, and also describes the policy as a scalable solution that will level the playing field nationwide.

“This bold step advances a circular economy that works for people, the planet, and the free market.”

National Stewardship Action Council, nonprofit advocacy group, statement on legislative passage, 24 April 2025

NSAC’s statement followed the Legislature’s final passage of the bill and urged the Governor to sign it.

Not every voice was supportive. The Washington Refuse and Recycling Association’s executive director described the programme as unproven in a 2025 radio interview, as reported by Packaging Dive on 24 April 2025, not confirmed in an official source18. SPI has not yet confirmed published comments on the draft from the Association of Washington Business, AMERIPEN, the Washington Beverage Association, Zero Waste Washington or the Northwest Grocery Association.

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.

Named organisations and streams exposed to the needs assessment, with the figures their own sources state
Organisation or streamExposureFigureSource
Carton Council (Elopak, Novolex, SIG, Tetra Pak)Carton tonnage in the draft21,272 tons, 2024, incl. self-haulCarton Council letter
Carton CouncilPer-person carton generation it derives5.29 lb per person per yearCarton Council letter
Circular Action AllianceReimbursement floor50% of net costs by 15 Feb 2030RCW 70A.208.170
Interchange360Alternative collection, automotive lubricant packagingRegistered, figure not statedEcology blog
HouseholdsCurbside recycling cost todayUSD 8 to 10 a monthEcology blog
Service providersDraft system cost, low confidenceAbout USD 432 per tonPublic comment, 19 Oct 2026

Source: Carton Council letter, 15 Oct 2026; Ecology blog, 15 Jul 2026; CAA release, 4 Mar 2026; public comment, 19 Oct 2026; RCW 70A.208.170, checked 31 Oct 2026.

Figures differ in year, unit and scope. Do not add them up or rank them. Draft figures cited by commenters are not yet confirmed by SPI in the draft. USD only.

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.

Ecology expects curbside recycling access to rise from 83% of residents to over 95%, and residential recovery from about 40% to 66% Unit: %
Ecology expects curbside recycling access to rise from 83% of residents to over 95%, and residential recovery from about 40% to 66%4 bars. Largest: Curbside access, expected, 95.Curbside access, expectedCurbside access, expected: 95 %95Curbside access, todayCurbside access, today: 83 %83Residential recovery, expectedResidential recovery, expected: 66 %66Residential recovery, todayResidential recovery, today: 40 %40Ecology expects curbside recycling access to rise from 83% of residents to over 95%, and residential recovery from about 40% to 66%4 bars. Largest: Curbside access, expected, 95.Curbside access, expectedCurbside access, expected: 95 %95Curbside access, todayCurbside access, today: 83 %83Residential recovery, expectedResidential recovery, expected: 66 %66Residential recovery, todayResidential recovery, today: 40 %40

Source: Ecology blog, 15 Jul 2026, citing state and regional studies, checked 31 Oct 2026.

Ecology's stated expectations from earlier studies, not findings of the draft needs assessment.

Show the data
Ecology expects curbside recycling access to rise from 83% of residents to over 95%, and residential recovery from about 40% to 66% (%)
MeasureShare (%)
Curbside access, expected95
Curbside access, today83
Residential recovery, expected66
Residential recovery, today40

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.

SPI analysis

The 90-day minimum leaves Ecology one day of slack between the 1 October draft and the 31 December deadline. Any further comment round would push the final past the statutory date, so producers should treat 30 October as the practical cut-off for this stage.

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.

Washington starts reimbursement a year after Minnesota on the same 50% to 90% path, while Colorado set 100% after its 2024 needs assessment
RuleJurisdictionRule titleFromStatus
PR-US-004CaliforniaCalifornia SB 54 packaging EPR and permanent regulations1 May 2026In force
PR-US-011CaliforniaCalifornia SB 343 recyclability labelling restrictions4 Oct 2026Adopted

Source: RCW 70A.208.110 and 70A.208.170; MPCA; Minnesota Statutes 115A.1450 and 115A.1455; CDPHE; SPI Regulation Tracker records PR-US-002, PR-US-003, PR-US-004, PR-US-006, PR-US-008, checked 14 Oct 2026.

Percentages are statutory minimum shares of net costs and are not comparable where bases differ. USD only; no figures are summed or ranked.

SPI analysis

Washington and Minnesota now share a template, with a needs assessment feeding a phased reimbursement floor and plans due on the same day in 2028. Colorado shows the end point: once the needs-assessment scenario was chosen, the full cost obligation followed within two years.

What it means for you

SPI analysis

These points follow from the sources above and are not legal advice; check with counsel on any filing or data question.

  • Brand owners: the needs assessment sets the cost base your CAA fees will fund from 2030. If your formats are in the draft’s material tables, check the tonnage before 30 October; the Carton Council’s letter shows that disputes start now, not at fee time.
  • Converters: design data matters for the 2027 full assessment, which must propose outcome ranges and recycled content potential by resin and film type. Prepare format-level recyclability and recycled content data for customers.
  • Material makers: in-state end markets and MRF capacity are both assessment items. Glass and PET buyers should watch the end-market findings, which commenters say are thin.
  • Retailers and grocers: a retailer that owns the brand on own-label packaging is first in line as producer under RCW 70A.208.020. From 1 March 2029, sellers face penalties for stocking goods from non-member producers after a warning.
  • Service providers: cost data you submit sets your reimbursement, and the draft’s cost figure is reported as low confidence. File cost data and request confidential treatment where needed.
  • Finance and investors: the reimbursement floor moves from 50% to 90% of net costs between 2030 and 2032. Ask portfolio companies for their Washington tonnage by material. A tonnage error corrected in the assessment now costs less than one carried into five years of plan fees.

Track PR-US-008, PR-US-006 and PR-US-003 among the 79 rules in the SPI Regulation Tracker, and model fee exposure in the SPI EPR & Plastic Tax Calculator. For the national picture, read US state packaging EPR.

Comments close on 30 October, and the reimbursement floor reaches 90% five years later
  • past
  • event
  • next
Comments close on 30 October, and the reimbursement floor reaches 90% five years later10 dated items from 17 May 2025 to 15 Feb 2032.202520262027202820292030203120322033Today17 May 2025: SB 5284 signed as Chapter 316, Laws of 20254 Mar 2026: CAA announced as Washington PRO1 Oct 2026: Initial collection lists due; draft preliminary needs assessment released30 Oct 2026: Comment period closes31 Dec 2026: Final preliminary needs assessment due31 Dec 2027: Full statewide needs assessment due1 Oct 2028: PRO plan due1 Mar 2029: Enforcement against non-member producers begins15 Feb 2030: Reimbursement of at least 50% of net costs15 Feb 2032: Reimbursement of at least 90% of net costsComments close on 30 October, and the reimbursement floor reaches 90% five years later10 dated items from 17 May 2025 to 15 Feb 2032.202520262027202820292030203120322033Today17 May 2025: SB 5284 signed as Chapter 316, Laws of 20254 Mar 2026: CAA announced as Washington PRO1 Oct 2026: Initial collection lists due; draft preliminary needs assessment released30 Oct 2026: Comment period closes31 Dec 2026: Final preliminary needs assessment due31 Dec 2027: Full statewide needs assessment due1 Oct 2028: PRO plan due1 Mar 2029: Enforcement against non-member producers begins15 Feb 2030: Reimbursement of at least 50% of net costs15 Feb 2032: Reimbursement of at least 90% of net costs
  1. SB 5284 signed as Chapter 316, Laws of 2025past
  2. CAA announced as Washington PROpast
  3. Initial collection lists due; draft preliminary needs assessment releasedevent
  4. Comment period closesnext
  5. Final preliminary needs assessment duenext
  6. Full statewide needs assessment duenext
  7. PRO plan duenext
  8. Enforcement against non-member producers beginsnext
  9. Reimbursement of at least 50% of net costsnext
  10. Reimbursement of at least 90% of net costsnext

Source: RCW 70A.208.060, 70A.208.110 and 70A.208.170; Ecology; SB 5284 bill summary; MPCA, checked 14 Oct 2026.

Show the data
Comments close on 30 October, and the reimbursement floor reaches 90% five years later
DateLabelCategoryLink
2025-05-17SB 5284 signed as Chapter 316, Laws of 2025pasthttps://app.leg.wa.gov/billsummary?BillNumber=5284&Year=2025&Initiative=false
2026-03-04CAA announced as Washington PROpasthttps://circularactionalliance.org/news-feed/circular-action-alliance-announced-as-the-producer-responsibility-organization-in-washington
2026-10-01Initial collection lists due; draft preliminary needs assessment releasedeventhttps://ecology.wa.gov/waste-toxics/reducing-recycling-waste/our-recycling-programs/recycling-reform-act/needs-assessments
2026-10-30Comment period closesnexthttps://ecology.commentinput.com/comment/extra?id=QbChArB7j&lang=en
2026-12-31Final preliminary needs assessment duenexthttps://app.leg.wa.gov/RCW/default.aspx?cite=70A.208.110
2027-12-31Full statewide needs assessment duenexthttps://app.leg.wa.gov/RCW/default.aspx?cite=70A.208.110
2028-10-01PRO plan duenexthttps://app.leg.wa.gov/RCW/default.aspx?cite=70A.208.060
2029-03-01Enforcement against non-member producers beginsnexthttps://app.leg.wa.gov/RCW/default.aspx?cite=70A.208.060
2030-02-15Reimbursement of at least 50% of net costsnexthttps://app.leg.wa.gov/RCW/default.aspx?cite=70A.208.170
2032-02-15Reimbursement of at least 90% of net costsnexthttps://app.leg.wa.gov/RCW/default.aspx?cite=70A.208.170

What to watch next

  • 30 Oct 2026: comment period on the draft preliminary needs assessment closes1.
  • 13 Nov 2026: comments close on Minnesota’s draft 2026 needs assessment, MPCA says.
  • 31 Dec 2026: final preliminary needs assessment due under RCW 70A.208.110; Ecology must respond in writing to advisory council and PRO comments.
  • 31 Mar 2027: Ecology sets the total annual registration fee for each PRO under RCW 70A.208.060.
  • 31 Dec 2027: first full statewide needs assessment due, including a recommended reimbursement rate methodology.
  • 1 Oct 2028: PRO plan due to Ecology, the same day as Minnesota’s stewardship plan.
  • 15 Feb 2030: reimbursement floor of at least 50% of service providers’ net costs6.

FAQ

When do comments close on Washington's preliminary needs assessment?

Ecology’s comment period runs from 1 to 30 October 2026. Comments are submitted online through Ecology’s comment portal. The final preliminary assessment is due by 31 December 2026.

What is the preliminary needs assessment for?

It records Washington’s current residential recycling system, including access, costs, tonnage, facility capacity and end markets, under RCW 70A.208.110. The full assessment due on 31 December 2027 then recommends how reimbursement rates are set. Both serve as baselines for performance targets.

How much will the PRO reimburse service providers?

RCW 70A.208.170 sets at least 50% of net costs by 15 February 2030, 75% by 15 February 2031 and 90% by 15 February 2032. Rates are updated annually and use cost data from the needs assessment. Ecology’s programme page describes the schedule as at least 90% from 2030.

Who has commented on the draft so far?

By 19 October 2026 two comments were public: the Carton Council’s letter of 15 October and a Seattle resident’s comment. The Carton Council says the draft overstates 2024 carton generation, put at 21,272 tons in the tables it cites.

How does Washington compare with Minnesota?

Both phase reimbursement from 50% to 90% of net costs, but Minnesota starts on 1 February 2029, a year earlier. Minnesota’s draft 2026 needs assessment takes comments until 13 November 2026, and both states’ plans are due on 1 October 2028.

Sources

  1. Washington Department of Ecology, Needs assessments (Recycling Reform Act), undated page (consulted 2026-10-20)
  2. Washington Department of Ecology, Draft Preliminary Needs Assessment, 1 October 2026; figures cited via public comments, not yet confirmed by SPI in the document (consulted 2026-10-20)
  3. Washington Department of Ecology, Recycling Reform Act, undated page (consulted 2026-10-20)
  4. Washington Department of Ecology, Recycling Reform Act will lower recycling costs in Washington state, 15 July 2026 (consulted 2026-10-20)
  5. Washington State Legislature, RCW 70A.208.110, Statewide needs assessments, in force from 27 July 2025 (consulted 2026-10-20)
  6. Washington State Legislature, RCW 70A.208.170, Service provider reimbursement, in force from 27 July 2025 (consulted 2026-10-20)
  7. Washington State Legislature, RCW 70A.208.060, Duties of department, in force from 27 July 2025 (consulted 2026-10-20)
  8. Washington State Legislature, SB 5284 (2025), bill summary, signed 17 May 2025 (consulted 2026-10-20)
  9. Washington Department of Ecology, Recycling Reform Act: Preliminary Needs Assessment, public comments, comments dated 15 and 19 October 2026 (consulted 2026-10-20)
  10. Carton Council, RE: Carton Council Comments Regarding Draft Preliminary Needs Assessment Report, 15 October 2026 (consulted 2026-10-20)
  11. Washington Department of Ecology, Request for Information to Develop Statewide Recycling Lists and Needs Assessments, 26-07-021, 1 April 2026 (consulted 2026-10-20)
  12. Circular Action Alliance, Circular Action Alliance Announced as the Producer Responsibility Organization in Washington, 4 March 2026 (consulted 2026-10-20)
  13. Product Stewardship Institute, Washington Adopts Packaging EPR Law, Marking Major Recycling Reform, 23 May 2025 (consulted 2026-10-20)
  14. National Stewardship Action Council, NSAC applauds Washington State Legislature’s passage of EPR for packaging, 24 April 2025 (consulted 2026-10-20)
  15. Minnesota Pollution Control Agency, Packaging Waste and Cost Reduction Act, undated page (consulted 2026-10-14)
  16. Office of the Revisor of Statutes, Minnesota, Minnesota Statutes section 115A.1455, Service provider; reimbursement, current text (consulted 2026-10-14)
  17. Colorado Department of Public Health and Environment, Producer Responsibility Program, undated page (consulted 2026-10-14)

Secondary (context only)

  1. Packaging Dive, EPR for packaging bill in Washington heads to governor, 24 April 2025 (consulted 2026-10-20)

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