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Oregon Packaging EPR: The Producer Guide for 2026

V. Jain · · 4 min read

Oregon EPR fees are already live - NorthEPR producer guide

Of all the US states moving to packaging EPR, Oregon is the one already collecting money. The state's Recycling Modernization Act is not a future deadline to plan around. It is live, invoices have gone out, and the state has already started enforcement. If you sell packaged food or beverage products in Oregon, this is the program to understand first.

What the law does

Oregon's Recycling Modernization Act (RMA), passed in 2021, shifts the cost of recycling from taxpayers and municipalities to the producers who put packaging into the market. The Oregon Department of Environmental Quality (DEQ) oversees the program, and it selected the Circular Action Alliance (CAA) as the producer responsibility organization that runs the day-to-day work: collecting producer fees and funding recycling system improvements statewide.

CAA began invoicing producers in July 2025, the first packaging EPR fees ever collected in the United States. Reporting from the federal court case over the program put the numbers at roughly $145.5 million collected from producers, which tells you something important: this is not a token registration fee. It is a material line item for anyone selling packaged goods in the state.

Who counts as a producer in Oregon

The obligated party is generally the brand owner: the company whose name appears on the package. The hierarchy runs brand owner, then licensee, then importer or distributor, then retailer. If your brand is on a kombucha bottle or a coffee bag sold in Portland, the obligation is probably yours.

There is a small-producer exemption. Producers under $5 million in Oregon gross revenue or under one metric ton of covered material per year can qualify for relief. Check the current CAA and DEQ guidance before assuming you qualify, because the definitions are specific and the thresholds are per legal entity, not per brand.

If you need the general framework first, our guide on who counts as an EPR producer walks through the producer hierarchy in detail. The concepts carry across jurisdictions even where the thresholds differ.

How the fees work

Oregon's fees are calculated from your reported packaging data. You report what you sold into Oregon: materials, weights, and formats. CAA then applies its fee schedule and sends assessments. The first invoices went out in July 2025, with further assessments following on a semiannual cycle, including January 2026.

Two things about this structure matter for producers:

  1. The data drives the bill. Inaccurate or incomplete packaging data does not just create paperwork risk. It directly changes what you pay. A producer that cannot break down packaging by material and weight is essentially guessing at its liability.

  2. The fee methodology has been contested. The National Association of Wholesaler-Distributors (NAW) sued in July 2025, arguing the fee methodology was opaque and the assessments were higher than projected. A federal district court granted a preliminary injunction for NAW members in February 2026, and the case went to trial in July 2026, with an appeal to the Ninth Circuit now underway. Whatever the outcome, the dispute itself is a lesson: know your fee basis before the invoice arrives, not after.

For a broader explanation of how these calculations work, see our piece on how EPR packaging fees are calculated.

Enforcement is already happening

Oregon DEQ sent warning letters to non-compliant producers in March 2026. That is the enforcement ladder working as designed: outreach first, then formal action. Producers who have not registered with CAA or reported their data are the ones hearing from the state.

The signal to take away is simple. Oregon is past the education phase. The state expects registration, data, and payment.

Your Oregon compliance checklist

  1. Confirm whether you are obligated. Brand on the package sold in Oregon means yes, unless an exemption clearly applies to your legal entity.
  2. Register with CAA if you have not already. Each legal entity registers on its own.
  3. Build a SKU-level packaging inventory. Every product, every component, every material, with weights. This is the foundation of every fee you will pay.
  4. Report accurately and on time. Errors in reported data follow you forward and can be expensive to correct later.
  5. Track the legal developments. The NAW case could reshape fee methodology or timing. Watch it, but do not use it as a reason to sit out: obligations continue while litigation runs.

Oregon is the preview

California, Colorado, Minnesota, Maryland, and Washington are all moving along their own timelines, and we already covered California's SB 54 fee start in detail. Oregon is simply the first one where producers have paid real money, and it is the clearest preview of what is coming everywhere else: data-driven fees, an active PRO, and enforcement that escalates.

We built NorthEPR to take this off your plate: software that shows where you have to report, what you owe, and gets your filings ready on time. We are opening 3 free pilot spots for a 2026 packaging-data health check plus first filing support. If Oregon is on your list of states, take a look at the pilot.