Oregon EPR Law: What Companies Selling Packaged Products Into Oregon Must Do
Oregon’s EPR law, formally the Plastic Pollution and Recycling Modernization Act (Senate Bill 582), requires certain producers of packaging, paper products, and food serviceware to participate in Oregon’s producer responsibility program. Companies that meet the definition of a producer must register with the Circular Action Alliance (CAA), report supply data, and pay producer fees.
For compliance teams, the challenge is understanding the statute, determining whether your organization qualifies as a producer, understanding your obligations, tracking reporting requirements, and staying current as regulations continue to evolve.
As more states adopt packaging EPR laws, maintaining compliance across jurisdictions becomes increasingly difficult without a centralized approach.
What Is the Oregon EPR Law?
Oregon’s EPR law was enacted to modernize the state’s recycling system by shifting a portion of recycling costs from local governments to the companies that introduce covered packaging, paper products, and food serviceware into the market. The program is overseen by the Oregon Department of Environmental Quality (DEQ) and administered through an approved producer responsibility organization (PRO), currently the CAA.
The EPR program aims to:
- Expand recycling access across the state
- Improve recycling infrastructure
- Reduce contamination in recycled materials
- Fund recycling through producer fees
- Hold producers responsible for the materials they sell
According to CAA, approximately 88 cents of every fee dollar goes directly toward collection, processing, and education and outreach activities.
Do You Need to Comply With the Oregon EPR Law?
If your company sells packaged products into Oregon, the first step is determining whether you qualify as a producer. Producer responsibility is generally assigned through a hierarchy based on factors such as brand ownership, importation, and how products enter the Oregon market.
Producer responsibility generally falls to:
- The manufacturer, when the item is sold under the manufacturer’s own brand or lacks a brand;
- The brand licensee, when another company manufactured the item;
- The importer, if neither of those parties is located in the United States.
For remote sales, the producer of packaging directly containing the product follows that hierarchy, while the company packaging and shipping the item is the producer of the shipping packaging. Food serviceware responsibility falls to the first seller in or into Oregon.
Do You Have EPR Exemptions Available?
Oregon recognizes both small-producer exemptions and product-specific exemptions.
A producer may qualify as a small producer if it meets any applicable statutory pathway, including:
- Operating as a nonprofit organization or public body
- Having less than $5 million in gross revenue during its most recent fiscal year
- Selling less than one metric ton of covered products in or into Oregon during the most recent calendar year
- Qualifying under the separate volume threshold for certain beverage manufacturers
- Operating as a qualifying restaurant, food cart, or similar establishment
- Operating one retail location, with no online sales, outside a franchise or chain
Associated producers may need to combine their revenues and covered-product volumes when determining whether an exemption applies. Qualifying small producers do not have to register with a PRO, report supply data, or pay producer fees.
Oregon also excludes specific materials from the covered-product definition. Examples include Bottle Bill beverage containers, bound books, certain industrial packaging, certain drug and medical-product packaging, and qualifying farm items. These exemptions vary in scope. For example, the Bottle Bill exclusion applies to the beverage container but does not automatically exclude secondary or tertiary packaging.
What Happens If You Determine You Must Comply With Oregon EPR Law?
| Obligation | What It Means | Timing |
| Register with CAA | Register with Oregon’s approved Producer Responsibility Organization | Upon determining you are an obligated producer |
| Supply Data Reporting | Report covered materials supplied into Oregon | May 31 annually. The 2025 supply data report was due May 31, 2026. |
| Producer Fees | Pay fees based on reported material volumes | CAA invoices producers in January. For Oregon’s 2026 program year, invoices were issued in January 2026 and payable in two 50% installments. |
| Life Cycle Impact Evaluations (Top 25 Producers Only) | Evaluate and disclose environmental impacts for at least 1% of covered products. | December 31, 2026 for most obligated large producers. |
| DEQ Rulemaking & Program Updates | Monitor Oregon DEQ rule changes, program amendments, and updated guidance. | Ongoing. Oregon’s third RMA rulemaking comment period closes October 30, 2026. |
Updated October 2026
Determining that your company is an obligated producer is only the first step. Once subject to Oregon’s EPR requirements, organizations take on ongoing responsibilities related to registration, reporting, fee management, and regulatory monitoring.
For many companies, compliance becomes a cross-functional effort involving legal, tax, sustainability, finance, operations, and product teams. Missing a registration, reporting deadline, or fee obligation can create regulatory risk, financial exposure, and significant remediation effort.
1. Register With Circular Action Alliance
Covered producers are required to participate through a PRO. In Oregon, CAA is currently the only approved PRO responsible for administering producer participation requirements.
Organizations that qualify as producers need to register with CAA and maintain their participation as program requirements evolve.
Once you’re registered in every state where you have obligations, CAA will communicate additional steps, including fees and data collection.
2. Report Covered Product Supply Data Every Year
Producers report the weight (in pounds) of each covered material they sold into Oregon via the CAA portal.
- The 2026 deadline to file Oregon’s EPR report was May 31, 2026. You may still file even after this deadline has passed, or risk non-compliance penalties. Be sure to work with CAA as quickly as possible to resolve the issue and mitigate compliance risk.
Reporting dates vary by state and program year. Producers should confirm each current deadline through CAA and the applicable state agency.
3. Pay Producer Fees
Producer fees are based on the covered material data reported to CAA. After submitting annual supply data, producers receive an invoice reflecting the quantity and type of covered materials they supplied into Oregon.
Oregon’s fee process operates on a lag. For example, 2024 supply data was used to calculate 2026 program fees. Likewise, the supply data producers reported in 2026 is used to establish their fee obligations for the 2027 program year.
Fee schedules are published in advance to help producers understand and prepare for future obligations. Producers should monitor CAA communications and invoices for applicable fee amounts, payment terms, and due dates.
What Happens If You Don’t Comply With Oregon’s EPR Law
Failure to meet Oregon EPR obligations can create both financial and public compliance exposure.
Oregon DEQ states that failing to register or become a member of an approved Producer Responsibility Organization is a Class 1 violation that can result in fines of up to $25,000 per day.
Oregon law also requires the PRO to maintain a searchable registry of compliant producer members and identify members that are currently out of compliance, including the reason for noncompliance. The registry must be updated at least quarterly.
If a producer member does not pay required fees or provide requested records or information, the PRO must notify DEQ within 30 days after a three-month period of unsuccessful collection efforts. DEQ may then use its established compliance and enforcement tools, including warnings, pre-enforcement notices, civil penalty assessments, and corrective orders as applicable.
For companies selling into Oregon, the risk is therefore not limited to a late report. Noncompliance can lead to escalating regulatory attention, financial penalties, public identification of an unresolved compliance issue, and significant internal effort to correct missing registrations, data, or payments.
How Oregon EPR Compliance Becomes Complex
Most companies know the law exists by now. Breakdowns happen when the work spreads across teams and calendars.
- Scattered data: Product teams hold packaging weights, legal holds brand ownership, and ERP systems hold sales by state.
- Recurring deadlines: Oregon requires an annual supply report and two fee invoices each year, and every new state adds its own dates.
- Changing rules: DEQ rulemakings and CAA fee schedules revise the requirements every year.
- Key-person dependence: When only one employee holds the process in their head, a departure stalls the next filing.
Manage Oregon EPR Obligations With ComplyIQ
As packaging EPR programs continue expanding across the United States, maintaining visibility into compliance obligations becomes increasingly difficult. See ComplyIQ in action and learn how organizations are centralizing obligations, tracking critical deadlines, and reducing compliance risk across jurisdictions.
Frequently Asked questions
This analysis is intended for informational purposes only and is not tax advice. For tax advice, consult your tax adviser. See the full disclaimer here.
