Oregon Is Rewriting Its Packaging Fee List. Comments Close Oct 19.

Oregon Is Rewriting Its Packaging Fee List. Comments Close Oct 19.

Oregon's packaging EPR program is barely a year old, and the rulebook is already being rewritten. The Circular Action Alliance, the producer responsibility organization that runs Oregon's program under the Recycling Modernization Act, has submitted its third program plan amendment to the Oregon Department of Environmental Quality. DEQ has opened it for public comment, and the window closes at 5:00 p.m. PT on October 19, 2026.

If you sell packaged products into Oregon, this one is worth your attention. Here is what is on the table.

What the amendment would change

According to DEQ's summary of the proposal, the amendment would:

• Change the covered material categories. This is the big one. Material categories are what your fees are calculated from, so any change here moves money.
• Let CAA update fees for glass packaging if regulations change. Glass fees have already been a fight in Oregon. This would give the fee schedule room to move.
• Update the Specifically-Identified Materials list. These are the hard-to-recycle materials that get special treatment in the program.
• Change a key performance metric from diversion rate to pounds of Uniform Statewide Collection List material collected per household.
• Update how collection events are sited.

In plain terms: the amendment reshuffles which materials count, how glass is charged, and how the program measures success. All of that flows through to what producers pay.

How to weigh in

Email your comments to RethinkRecycling@deq.oregon.gov by 5:00 p.m. PT on October 19, 2026. The notice is posted in the Program updates section of DEQ's Recycling Modernization Act page.

Producers do not comment on these windows nearly as often as they should. The material categories in this amendment are the same categories your future fees will be calculated from. If a category your packaging falls into is being redefined, now is the time to say something, not after the invoice arrives.

One more Oregon window

A second comment window is running in parallel. DEQ's third RMA rulemaking is open for comment until 4:00 p.m. on October 30, 2026, with virtual public hearings on October 20 (10 a.m.) and October 21 (6 p.m.). Comments go to RMARulemaking3@deq.oregon.gov. That rulemaking covers the longer-term rule updates, including the recycling acceptance lists and fee exemptions.

Why this matters beyond Oregon

Oregon was the first US state to implement packaging EPR, and its program is the template other states study. When Oregon redefines material categories, the logic tends to travel. California, Colorado, Minnesota, and Washington all run through the same PRO, the Circular Action Alliance, and harmonization pressure is real.

The practical move is the same as always: know exactly what packaging you put into each market, by material and weight. Fee schedules change. Clean data does not go stale.

We built NorthEPR for exactly this: software that helps food and beverage producers figure out where they have to report their packaging, what they owe, and get their filings ready on time. We are opening 3 free pilot spots right now: a 2026 packaging-data health check plus first filing support. Take a look at the pilot.