As the March 31, 2025, reporting deadline for Oregon's Extended Producer Responsibility (EPR) program approaches, producers must be aware of key requirements to ensure compliance. This program is designed to hold producers accountable for the environmental impact of their packaging materials. Ideally, your organization has already made progress in this area, if not, here’s what you need to know:
Determination of Small Producer Status
Some producers may not be obligated to report in Oregon if they qualify for small producer status. To qualify as a small producer, an organization must meet at least one of the following criteria:
Have a gross global revenue of less than $5 million for the most recent fiscal year.
Have sold in or into Oregon less than one metric ton of covered products for use in this state in the most recent calendar year.
Operate a single retail establishment with no online sales and not be part of a franchise or chain.
Be a non-profit organization.
Be a public body.
If your company's legal counsel determines that your company is obligated to report, your next step is registration.
Registration with a Producer Responsibility Organization (PRO)
Producers must register with the Circular Action Alliance (CAA), currently the only PRO of record in Oregon. CAA is a producer-led organization with founding members that include Kraft Heinz, Amazon, Colgate-Palmolive, General Mills, S.C. Johnson, Target, and more. Once you have registered, you will have to sign a Participant Producer Agreement (PPA), then you will be granted access to the online reporting portal.
Signing the State Addendum
To ensure compliance and successfully submit packaging data, producers must sign the state addendum as required by the Oregon Department of Environmental Quality (DEQ). This will be available in your online portal.
Oregon EPR Reporting Obligations
Producers must report data for all covered materials sold or distributed in Oregon during the 2024 calendar year. This includes detailed information on the weight, quantity, and material categories of packaging, printing and writing paper, and food serviceware.
Unlike Canadian packaging EPR programs, Oregon’s EPR system also includes transport (tertiary) packaging in its reporting requirements.
Fee Payment
After submitting reports, producers will be required to pay fees associated with managing their packaging waste. The official fee schedules are expected to be released in June 2025, with payments due by July 2025.
Exemption Claims
Some products may qualify for an exemption if they are already covered under another recycling program, do not undergo separation from other materials at a commingled recycling facility, or are recycled at a responsible end market.
If seeking exemptions under ORS 459A.869 (13), producers must submit the necessary claim forms and supporting documentation to DEQ by March 7, 2025, at 5 p.m. PT.
Preparation and Compliance
Once registered with CAA, producers gain access to the Producer Resource Library, which includes detailed reporting guidance.
Regularly consult official resources from DEQ and CAA for updates and additional guidance. Webinars and other learning materials are available on CAA’s Producer Resource Library to assist in compliance.
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By following these requirements and utilizing available resources, producers can successfully meet Oregon’s upcoming EPR reporting deadline while contributing to a more sustainable and transparent packaging system. Please reach out to Circular Action Alliance at Producer.Support@CircularAction.org if you are not yet registered to report.
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