Oregon packaging EPR: the Recycling Modernization Act
In short
If you are the brand owner of packaged goods sold in or into Oregon, you are likely the obligated producer under Oregon's Recycling Modernization Act. Registration and reporting run through Circular Action Alliance, the state's only approved producer responsibility organization. Supply data for each calendar year is due to CAA by May 31; the next deadline is May 31, 2027, covering 2026 data. This is general information, not advice about your company: confirm every deadline with CAA or Oregon DEQ before acting, because dates can change.
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Who is obligated
Oregon's program covers packaging, paper, and food serviceware. For a food or beverage brand selling packaged goods into Oregon, the obligated producer is the brand owner. The statute sets a cascade: the manufacturer if it sells under its own brand, otherwise the brand owner or trademark licensee, and if neither is in the United States, the importer. Online sellers count too: packaging sold online makes the person who packages and ships the item to the consumer the producer. (ORS 459A.866; DEQ producers page)
Key dates
- May 31, 2027: Annual supply report due to CAA, covering calendar year 2026 data.
- January 2027: Payment date for the 2027 program year fees.
- Program launched July 1, 2025. Producers who have not yet reported 2024 or 2025 supply data are, per DEQ, likely out of compliance and should report immediately.
Where to file
With CAA, not DEQ. Producers sign CAA's Producer Participant Agreement with the Oregon addendum, then report through CAA's Producer Portal. (CAA producer reporting)
Program and regulator
Circular Action Alliance is Oregon's only approved producer responsibility organization, approved by Oregon DEQ on February 21, 2025, with a program plan for 2025 to 2027. DEQ oversees CAA's implementation and runs enforcement, including formal warning letters and a public noncompliance list. (DEQ producers page)
Fees
2025 was the first fee year and fees were invoiced. CAA published the 2026 Oregon producer fee rate schedule in October 2025, with invoices estimated for January 2026 in two installments. Final per-ton rates live on CAA's registration-restricted portal. (CAA producer resource center)
Small-producer relief
Oregon law defines a small producer as one meeting any single condition, including: gross revenue of less than $5 million for the most recent fiscal year, or less than one metric ton of covered products sold in or into Oregon in the most recent calendar year. DEQ confirms small producers are exempt from producer obligations under the Act. (ORS 459A.863(32))
Penalties
Violations carry a civil penalty of up to $25,000 per day per day of violation under ORS 459.995. Overdue CAA payments can incur a late charge of up to 1% per month, compounded monthly.
Frequently asked questions
Do I file with DEQ or with CAA?
This is general information, not advice about your company. You register and report with CAA, the approved producer responsibility organization. DEQ oversees the program and enforces compliance, but it does not take your supply reports.
I missed the earlier deadlines. What now?
This is general information, not advice about your company. Per DEQ, producers who have not reported 2024 or 2025 supply data are likely out of compliance and should report immediately. The next regular deadline is May 31, 2027.
Does Oregon's small-producer test use Oregon revenue or global revenue?
This is general information, not advice about your company. The statute says gross revenue of less than $5 million for the organization's most recent fiscal year, and a DEQ rulemaking memo phrases it as gross (global) revenue. If you are near the line, confirm with CAA or DEQ before assuming you qualify.
How does NorthEPR help with Oregon?
This is general information, not advice about your company. NorthEPR evaluates your packaging catalogue against Oregon's rules, estimates your fees from published schedules, and prepares a draft supply report you review and file yourself in CAA's portal.
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