Oregon was the first U.S. state to actually enforce an extended producer responsibility (EPR) program for packaging, and that head start means Oregon’s rules are now the template other states are copying. If your brand ships packaged products, printed paper, or food serviceware into Oregon, you likely have obligations under the state’s Recycling Modernization Act (RMA) — even if you’re based somewhere else entirely.
This guide breaks down what the law covers, who’s exempt, and the practical steps to register, report, and pay without getting hit with penalties.
Quick Answer
Oregon’s EPR packaging law — created by Senate Bill 582, the Plastic Pollution and Recycling Modernization Act — requires most companies that sell packaged goods, printing/writing paper, or food serviceware into Oregon to join a producer responsibility organization (PRO), report their packaging data, and pay fees that fund the state’s recycling system. The law’s producer obligations took effect July 1, 2025, and Circular Action Alliance (CAA) is the state-approved PRO handling registration, reporting, and fee collection on producers’ behalf.
Who Has to Comply, and What Counts as “Covered”
A “producer” under the RMA is generally the company that brands or sells the covered product in Oregon — for most online and retail sellers, that’s whoever owns the brand on the package, not the contract manufacturer. Covered products include packaging materials (boxes, bags, wraps, cushioning, labels), printing and writing paper, and food serviceware such as cups, plates, and takeout containers. Shipping and moving materials like packing boxes and mailers are covered too.
Beverage containers already regulated under Oregon’s bottle deposit law are excluded, since they’re funded through a separate system. Oregon also built in a small-producer exemption: a company can qualify as exempt if it meets at least one of several alternate criteria, the two most commonly used being under $5 million in global annual revenue or less than roughly one metric ton of covered material sold into Oregon per year. Exempt producers don’t need to join a PRO, report tonnage, or pay fees — but it’s worth confirming exemption status with CAA directly rather than assuming, since the criteria are specific.
Non-compliance isn’t a minor risk: Oregon DEQ has enforcement authority, and legal advisories following the compliance deadline have flagged potential penalties running into the tens of thousands of dollars per day for producers that fail to register or report.
How to Register, Report, and Pay
Start by confirming whether your company meets the small-producer exemption. If it doesn’t, the first real step is registering as a producer with Circular Action Alliance through its producer portal — this is the only step DEQ approved as the state’s PRO, so there’s no separate state registration to track down.
Reporting runs on an annual cycle: producers report the prior year’s packaging and material data (type, weight, recyclability) to CAA. The very first reporting cycle covered 2024 supply data and was due by March 31, 2025, but going forward the annual deadline has moved to May 31 each year — so 2025 supply data is due by May 31, 2026, and that becomes the recurring date to plan around. CAA uses that data to calculate your fee obligation, which is billed in installments across the year, so budgeting for next year’s dues should happen well before the reporting deadline, not after.
Fees aren’t flat per pound. Oregon’s system includes eco-modulation, meaning producers can reduce what they owe by using packaging that’s more recyclable, contains post-consumer recycled content, or is otherwise designed to perform better in Oregon’s collection system. Larger producers also face added lifecycle-assessment (LCA) disclosure requirements tied to eco-modulation credits, with phased deadlines rolling out through 2026.
Tips / Common Mistakes
Don’t assume being headquartered outside Oregon lets you off the hook — obligation is based on where the packaged product is sold, not where the company sits. E-commerce and marketplace sellers shipping into Oregon are squarely in scope.
Don’t wait until the annual reporting deadline to pull your packaging data together. Material-level reporting (weights across dozens of material categories) requires input from packaging suppliers and manufacturers, and that data collection takes longer than most teams expect the first year.
Don’t ignore the exemption fine print. Companies sometimes assume they’re too small without checking the actual criteria, or assume they’re exempt indefinitely without re-checking as revenue or volume grows.
Don’t treat this as a one-state problem. California, Colorado, Maryland, Minnesota, and Washington have passed similar EPR packaging laws and now share the same May 31 CAA reporting deadline Oregon uses — so the systems and data you build for Oregon compliance will likely be reused elsewhere.
Explore more: More packaging compliance guides.
Oregon EPR Packaging Law (RMA) FAQs
When did Oregon’s EPR packaging law take effect?
Producer obligations — joining a PRO, reporting, and paying fees — took effect July 1, 2025, though registration and 2024 data reporting with Circular Action Alliance began earlier in 2025.
Who is the PRO for Oregon’s packaging EPR program?
Circular Action Alliance (CAA) is the only producer responsibility organization approved by Oregon DEQ, and it handles registration, reporting, and fee collection for producers.
When is the annual reporting deadline?
After the first cycle (2024 data, due March 31, 2025), the recurring annual deadline moved to May 31. Producers must report their 2025 supply data to CAA by May 31, 2026, and that date repeats each year going forward.
Is my small business exempt from Oregon’s EPR law?
You may qualify for the small-producer exemption if you meet at least one alternate criterion, such as under $5 million in global annual revenue or very low covered-material tonnage sold into Oregon. Confirm your specific status with CAA rather than assuming.
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Photo by Ari Gardinier on Unsplash.