Key Takeaways

• We have over 2,657 producers registered as of Jan. 21, 2025, and more continue to join each day.

• The extension of the public comment period on Oregon’s Program Plan 3 has delayed the finalization of some key elements that inform the Reporting Portal and the Oregon State Addendum. The Oregon State Addendum will be issued upon approval of the Oregon Program Plan which is expected in mid-February.

• To support producer readiness, CAA is offering weekly producer portal demonstration and training sessions. The Oregon 2025 Report Preparation Workbook allows producers to simulate the reporting portal submission prior to formal submission in CAA's producer portal. The third installment of our reporting guidance, Oregon Material Categories & Definitions, provides additional details on definitions, examples and reporting tips for each reporting category. Portal credentials will be issued in early February. We appreciate your patience as we work to incorporate all final elements from the Oregon DEQ's review of the Program Plan into the portal.

• Materials are reported in aggregate, and you'll need to consider what each component is made of and if they are separable from each other. If all the components are made of the same material, then you will report them together. If the components are not made of the same material and cannot be separated, then they should be reported in the category representing the material type that makes up the majority of their combined weight. You will report the total of the combined weight.

• If the packaging or food service ware has two or more sides measuring 2" or less, report the material under the "small format" category in the corresponding covered material category (plastic, metal, etc).

• In general, Oregon and California require that you report both Business-to-Business and consumer packaging. This is true for all materials that are covered and may be used in a B2B setting, including secondary, tertiary and shipping materials that are part of the material lists.

Q&A Overview

• What outreach methods are you using to increase registration compliance?

  Circular Action Alliance is committed to registering as many obligated producers as possible prior to any statutory deadlines. In the last 12 months, we have invested in paid and earned media outreach, spoken at relevant and targeted conferences, conducted targeted email campaigns, and built partnerships with many relevant trade associations. The priority of the Producer Services team is to target large producers that cover the majority of the supply of covered materials into the market, while also taking broad outreach tactics to secure registration from all obligated producers. After March 31, if additional producers are identified and retroactively contribute to their obligation, CAA can adjust fee rates in future periods to offset the initial fee payments.

• If we have subsidiaries, should we register, sign the PPA and report separately? Do the contacts have to be the same for the parent and the subsidiaries?

  Register: Each subsidiary should complete the registration form with Circular Action Alliance, CAA. If this is a major issue for your company, please contact producer.support@circularaction.org immediately to speak with CAA Producer Services about an exception request.

  Sign the PPA: We have the option for some parent companies to sign a PPA at the parent level that represents all subsidiaries. Complete this survey to request a single PPA. This does not allow the parent to report for all subsidiaries at the parent level – this is only for the PPA.

• What is the difference between an associated producer and a subsidiary?

  Associated producers are two or more producers that are legally intertwined in some way. This can be wholly owned subsidiaries, or partially owned subsidiaries, where 50% is owned or controlled by a trust or a person who is a grantor of the trust, share a single owner, or 50% of a company is owned by another entity.  You can find all the scenarios listed near page 39 of this guidance document.

  A subsidiary is a scenario within the definition of associated producer. 

  In both cases, it needs to be clear during the reporting process which entity is reporting which data.

• Does the small format criteria trump the packaging material type?

  Yes. No matter the material type, small formats should be reported in the Small Format categories due to how the size of a package affects its recyclability at MRFs.

• We receive the component materials of our products from multiple suppliers. How should we report?

  All the components that are sold together to the end consumer as a part of the paper or packaging are the responsibility of the brand owner of the product, except for shipping materials that are added. You should work with your suppliers to provide you with the weight and material type per component, and you should report the aggregate of your portfolio. If this information is not available by March 31, CAA has provided other accepted methodologies in our guidance. Shipping materials that are added to a finished product are the responsibility of the entity that added those shipping materials prior to sending to the end consumer or customer.

• If we have some materials that are covered and others not in scope, how is that handled?

  You should report on the materials that are covered, and you should exclude the non-covered products and packaging in your reported weights.

• We have had private label customers ask for packaging weight data. When must we supply them with data?

  Ideally, you should supply data to any of your partners with enough advanced time for them to complete their reporting and submit their material supply data on time. This helps all covered materials be accurately reported and promotes fair and equitable fee rates for all producers.