Short answer: Oregon's Recycling Modernization Act requires producers of packaging, paper products and food serviceware supplied into Oregon to join an approved Producer Responsibility Organization, report supply data and pay fees. The program is live: Circular Action Alliance began charging fees on July 1, 2025, and producers now report prior-year supply data each year by May 31.
What the Recycling Modernization Act is
The Oregon legislature passed the Recycling Modernization Act (Senate Bill 582) in 2021, and it took effect January 1, 2022. The Oregon Department of Environmental Quality (DEQ) oversees the program. Recycling program changes began in July 2025, funded in large part by producers of covered products.
Program facts
Current status, as published by Oregon DEQ
- Circular Action Alliance (CAA) is currently Oregon's only approved Producer Responsibility Organization. DEQ approved CAA's 2025 to 2027 program plan on February 21, 2025, and has since approved plan amendments.
- CAA was allowed to begin charging producer fees on July 1, 2025.
- Beginning May 31, 2026, prior-year supply data is due to CAA on or before May 31 each year. DEQ states that producers that have not reported 2024 or 2025 supply data are likely out of compliance.
- Failure to register or join a PRO is a Class 1 violation, with fines of up to $25,000 per day.
- DEQ is conducting further rulemaking; public hearings were held in October 2026, with final proposed rules expected to go to the Environmental Quality Commission in early 2027.
Registration and reporting, conceptually
Oregon producers participate by registering with CAA, reporting the covered products they supplied into Oregon, and paying the membership fees CAA invoices. The annual cycle is straightforward on paper: gather the prior year's supply data, submit it to CAA by May 31, and pay fees on CAA's schedule. DEQ publishes a decision tree to help companies work through whether, and how, they are obligated.
Covered products and the data behind them
Covered products include packaging, paper products and food serviceware. Reporting requires the weight of covered material supplied into Oregon, organized by the material categories CAA uses. That means you need:
- Units supplied into Oregon by SKU for the data year.
- Component-level packaging weights and materials for each SKU.
- A defensible method for allocating sales that reach Oregon through distributors or retailers outside the state.
Producer fees and material lists
DEQ explains that fee rates are allocated based on producer supply and change annually, and that fee payment deadlines are set by CAA. Because fees depend on reported quantities by material, the quality of your packaging data directly affects what you pay. Oregon also maintains statewide rules about which materials are collected for recycling, which influences how materials are categorized and, in turn, how they are charged. See how packaging EPR fees are calculated.
DEQ also runs an annual claim window, in the first quarter, for private recycling exemption claims using prior-year data that apply toward the next year's fees.
Large producer obligations
Under ORS 459A.944(2), the 25 largest producers by weight of covered product must conduct and disclose life cycle impact evaluations on a share of their covered products every two years. DEQ lists the first batch of disclosures as due December 31, 2026. Most growing brands will not fall into this group, but it signals the direction of the program.
Exemptions
Small producers, as defined in ORS 459A.863(32), are exempt. The definition turns on specific criteria in the statute, so confirm it against the statutory text and DEQ guidance rather than relying on summaries. Other exemptions apply to particular product types and situations.
CertaRelay recommendation
If you supplied products into Oregon in 2024 or 2025 and have not reported, address it now. Reconstructing historical supply data is far easier while sales records and packaging specs are still current.
Recurring data maintenance
Oregon is an annual obligation. Each year, sales change, SKUs launch and retire, and packaging gets redesigned. Producers that rebuild their data from scratch each spring spend more time and introduce inconsistencies. A maintained packaging ledger, with versioned components and dated changes, makes the May 31 submission a refresh rather than a project.
What your team should prepare
- Units supplied into Oregon by SKU for the prior calendar year.
- Component-level packaging specs: material, format and weight.
- Your CAA registration status and any prior Oregon reports.
- Distributor and retailer sales data that can support allocation to Oregon.
- A list of packaging changes made during the year, with effective dates.
How CertaRelay helps
- Build Oregon-ready supply data from your sales exports and packaging records.
- Reconstruct prior-year data where reports were missed, with documented assumptions.
- Prepare filing-ready outputs for CAA and track the annual May 31 cycle.
- Maintain a versioned packaging ledger so each year is a refresh, not a rebuild.
- Forecast Oregon fee exposure as rates update.
Program facts above are drawn from Oregon DEQ. Recommendations are CertaRelay's practical guidance.