Short answer: Registering with Circular Action Alliance (CAA) establishes your participation with the Producer Responsibility Organization in the states where CAA operates. It does not, by itself, complete your obligations. You still need to report supply data, pay fees or dues, keep records, meet each state's own requirements and repeat the cycle every year.
What CAA is
Circular Action Alliance is the approved or designated Producer Responsibility Organization in California, Colorado, Oregon, Minnesota, Maryland and Washington, according to the respective state agencies. Maine uses a different model: the Maine DEP contracts with a stewardship organization. See the State Hub.
What registration does
- Identifies your company to the PRO as a producer in one or more states.
- Starts the relationship through which you receive reporting requests, templates and invoices.
- Is often the step that keeps you eligible to sell where programs restrict non-participants, such as Colorado, which requires participation to sell or distribute products using covered materials.
What registration does not complete
| Still required | What it involves |
|---|---|
| Supply reporting | Reporting the packaging you supplied into each state, by material category and data year. In Oregon, prior-year data is due to CAA by May 31 each year. |
| Packaging data | Component-level materials and weights for each SKU, tied to state sales. Registration collects company details, not your packaging records. |
| Fees and dues | Paying invoices based on your reported quantities. Colorado dues on covered materials began January 2026. |
| State-specific steps | California uses CalRecycle's PEPRS portal for registration, data submission and compliance tracking alongside PRO participation. Check each state. |
| Exemption documentation | If you believe you are exempt in a state, documenting the basis, and any required application, is separate. |
| Annual repetition | Reports and fees recur every year. SKUs, suppliers and packaging change in between. |
| Other programs | Some products fall under separate programs, such as Colorado's automotive lubricants program. |
A common misunderstanding
Many brands register, receive a confirmation and assume they are done. Months later a reporting request arrives asking for weights by material for every SKU sold into the state, and the real work begins under a deadline. Registration is the front door, not the finish line.
CertaRelay recommendation
Treat registration as the trigger to start building your packaging record, not as the end of the project. The data work takes longer than the registration form.
How CertaRelay helps
CertaRelay supports registration and then handles what comes after: supplier data, packaging records, report preparation and deadline management. Your company keeps control of its accounts and approves every submission. See Managed Packaging EPR Operations or check where you stand with the free exposure check.