Oregon
The Plastic Pollution and Recycling Modernization Act requires producers of residential and commercial packaging, printing and writing paper, and food serviceware to join a Producer Responsibility Organization (PRO) and, through the PRO, fund the end of life management of those materials, which includes processing and recycling.
CAA is the only PRO with an approved program plan in Oregon. The Oregon Department of Environmental Quality (DEQ) approved CAA’s plan on Feb. 21, 2025.
FAQ
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Yes. All three drafts of the program plan can be found at the links below. They are also available on DEQ’s website.
March 31, 2024, initial program plan
September 27, 2024, revised program plan
December 6, 2024, final program plan
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Extended Producer Responsibility (EPR) is a policy approach that shifts financial and sometimes operational responsibility for the recycling/end-of-life management of a product to the companies that produce the material.
EPR laws for paper and packaging require producers (i.e., generally brand owner of the product in the U.S., may include retailers or first importers) to either partially or fully fund the collection, sortation and processing of the paper, packaging and packaging-like items that they supply into these states.
Since producers are made responsible for the costs to manage their product/packaging at end-of-life, EPR fees typically incentivize design choices that improve recyclability, minimize waste, and improve environmental outcomes.
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A Producer Responsibility Organization (PRO) is a producer-led, nonprofit organization that provides producers with compliance services to help them meet their obligations under EPR laws.
Generally, a PRO is responsible for developing a program plan for managing covered products. That plan is reviewed by a state-appointed advisory board and approved by the state regulatory agency. The program plan outlines program operation and the collection and management of producer fees.
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Under the RMA, local governments retain responsibility for funding and managing curbside recycling collection and delivering educational programs. Producers of covered products, through the Producer Responsibility Organization (PRO), provide funding to support existing material processing costs and some transportation costs. The PRO also funds certain system improvements and innovations, and both funds and manages the collection of certain materials through a depot system.
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The ultimate goal of RMA implementation is a transformed system of materials usage and recovery that will be responsive to the needs of all stakeholders and that will lead to significant environmental and social benefits.
The RMA cannot reach its full potential without a well-functioning PRO working with local governments, waste and recycling service providers, material processors, end markets, state officials and other links in the materials chain. CAA believes that successful implementation will achieve four high-level goals:Reduce negative environmental, social and health impacts from end-of-life management of products and packaging.
Increase the diversion of recyclable materials from disposal.
Improve public participation, understanding and equity in the state’s recycling system.
Create a system that fulfills the needs and regulatory requirements of the PRO, its members and all other relevant stakeholders.
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At a high level, CAA uses the fees that producers of covered products pay to ensure compliance with RMA requirements. While the RMA is broad-reaching and touches almost every part of Oregon’s recycling system, some of the most visible initiatives paid for by fees include statewide education and outreach campaigns, expanded recycling access to more communities – especially in rural Oregon – and a new network of recycling depots and collection points where recyclers can drop off materials not accepted in their curbside recycling bin.
Fees will also change what happens behind the scenes of recycling, including upgrades to the facilities that sort Oregon’s recycling, reimbursements for the transportation of some recyclables and verification that recycling goes to REMs to be turned into new feedstocks.
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The RMA applies to materials from residential and commercial sectors. Broadly, covered materials include packaging, food serviceware, and printing and writing paper. At a high level, Oregon's program splits recyclable materials into two lists:
Uniform Statewide Collection List (USCL): This list is approved for commingled collection, often at the curb through on-route collection, but also collected at depots, events and return to retail.
PRO acceptance list: These materials will be collected at recycling depots and other collection points, like retail stores and community recycling events.
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One of the key changes in Oregon’s improved recycling system under the RMA is the introduction of new measures to ensure collected materials are recycled at Responsible End Markets (REMs). REMs are the markets that receive and responsibly turn recyclables into raw materials or feedstocks for new products. CAA must verify that end markets processing Oregon materials comply with new REM standards and take action to address any practices that do not meet these standards. CAA will also be responsible for tracking and tracing recyclable commodities from Oregon, ensuring that Oregonians' recycled materials are not creating environmental burdens for other communities.
CAA has developed a detailed REM verification standard with specific criteria, performance indicators, and non-compliance procedures. CAA’s program plan provides an overview of the REM standard methodology.
For the initial phase of REM verification, CAA intends to partner with a third-party certification organization to ensure that CAA can effectively adapt the proposed methodology, confirm consistency of auditing and reporting in the initial phase, and prepare for integration with multiple certifications when they are independently available to end markets.
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Producers should register with CAA now to participate in educational forums and events geared toward producer preparation. CAA has also developed guidance materials to provide more detailed reporting instructions. Producers can access this guidance upon signing a Participant Producer Agreement (PPA) with CAA, which has a CAA deadline of Dec. 31, 2024. CAA also plans to launch a producer reporting portal to begin collecting producers’ data in Q1 2025.
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To set fees accurately, CAA must know the total system costs, the number of covered producers, and the total producer supplied tons by material type. Until producers register and report the actual weight of materials sold into Oregon in Q1 of 2025, CAA can only provide fee estimates. The draft three program plan offers an updated draft base fee schedule encompassing 60 material categories as well as updated system costs based on the results of extensive research efforts to understand system expansion, transportation, and depot system costs.
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The final draft of the program plan includes an estimated range for fee rates for both low and high fee rate scenarios. While both scenarios represent estimated total reported supply by producers, the low fee rate scenario represents a larger estimate of the total reported supply across all producers, and the high fee rate scenario represents a smaller estimate of the total reported supply across all producers. The principle is that if more material is reported, the total system costs can be spread across a larger supply base, resulting in lower overall fees.
Producers that qualify as low-volume producers may opt for a simplified flat fee, while larger producers are assessed fees based on their specific reported material weights. Accurate reporting is crucial, as final fee rates are adjusted annually based on this data. CAA will conduct validations to ensure accurate reporting by producers, and producers must substantiate their reported supply data to CAA upon request.
Producers will report Oregon supply data for the full calendar year 2024 (Data Year) on March 31, 2025 (Report Date).
Key Milestones in the Regulatory and Implementation Process
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February 21, 2025
Oregon DEQ Approves CAA’s Program Plan.
Local Government Resources
Funding Agreements
CAA has finalized the Primary Funding Agreement (PFA), and it is ready for your organization’s signature. As a reminder, a PFA must be signed by both the recipient and CAA to receive payment or reimbursement from CAA. This includes all communities, service providers and organizations. An individual addendum will be signed for each funding area (i.e., roll carts, glass incentive, etc.) at a future date.
Thank you to the many people who provided feedback on the PFA. If you have questions for the legal team as you review the PFA, please reach out to CAAFunding@millernash.com. The addenda for system expansion funding, USCL and PRO depots are expected to be finalized later this month. Other addenda will be posted here as they are finalized.
