Oregon
The Plastic Pollution and Recycling Modernization Act requires producers of residential and commercial packaging, printing and writing paper, and food service ware to join a Producer Responsibility Organization (PRO), and through the PRO, fund the end of life of those materials, which includes processing and recycling.
CAA is preparing to be the PRO in Oregon. On April 1, 2024. CAA was the only prospective PRO to submit a program plan to DEQ.
FAQ
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The program plan can be downloaded here and is also available on the DEQ website.
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Oregon’s Plastic Pollution and Recycling Modernization Act (RMA) creates important changes in how materials management is undertaken and funded within the state. The legislation strives to improve the overall effectiveness of Oregon’s recycling collection and processing ecosystem through a shared responsibility model.
The RMA was passed in 2021 and the program will be operational beginning July 1, 2025.
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CAA is preparing to be the PRO in Oregon. On September 1, 2023, CAA provided the Oregon Department of Environmental Quality (DEQ) with a letter of intent indicating it planned to submit a program plan. On April 1, 2024. CAA was the only prospective PRO to submit a program plan to DEQ.
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CAA’s producer registration deadline is July 1, 2024.
To register, producers must complete CAA’s Covered Producer Registration Form. To ease producer compliance, CAA is working to register all producers in Colorado, California, and Oregon by July 1, 2024.
Early producer registration helps:
* Reduce the number of non-compliant obligated producers in the system; and
* Provide CAA with more precise producer data to inform accurate and fair fee schedules.
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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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Throughout 2024 CAA will reach out to local governments and other stakeholders to design and implement key program elements. CAA has initiated a System Optimization Project that will build on an earlier study commissioned by the state to understand local government expansion requests. The engagement with local governments during the System Optimization Project will gather information about the current system, to allow for gaps to be identified along with necessary investments, and to create a schedule for efficient investment that will span through 2027.
Oregon DEQ will also consult with the Oregon Recycling System Advisory Council (ORSAC), a multi-stakeholder group convened by DEQ, to assess CAA’s proposal. The state agency will present feedback and requested revisions to CAA by July 31, 2024.
CAA will continue to move forward on RMA implementation strategies and refine key details, such as program costs and associated fee schedules.
CAA anticipates submitting an updated program plan, integrating DEQ’s recommendations and revisions, by the end of September of this year.
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No. CAA’s program plan includes an initial fee schedule. Fee rates will be refined in an anticipated second program plan and finalized by May 2025 before the program starts. Given a current lack of supply data and uncertainty about the cost of certain program elements, initial fee rates will be updated as more data becomes available.
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Additional data and information are needed to finalize both CAA’s budget and the fee schedule based on that budget. A critical requirement to setting an accurate fee schedule is producer supply data, which CAA won’t collect until March 2025. Prior to March 2025, CAA will work to refine the fee schedule as much as possible, including the inclusion of a new fee schedule as part of a second program plan submission in September 2024.
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The statute does not specify a date by which producers must first report data to CAA.
CAA will propose reporting requirements in its program plan.
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Producers should make sure they are registered with CAA ahead of the July 1, 2024, deadline. CAA also recommends that producers begin reviewing the draft list of 62 draft reporting categories included in CAA’s Oregon program plan. While the 62 categories are still subject to DEQ approval, CAA anticipates that the categories will stay sufficiently stable for producers to begin reviewing the categories. CAA is developing a guidebook to assist producers with data preparation and reporting, which will be shared with producers later in 2024.
Key Milestones in the Regulatory and Implementation Process
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August 6, 2021
Governor Brown Signs SB 582.
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September 1, 2023
CAA Submits a Letter of Intent
to Provide a Program Plan. -
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April 1, 2024
CAA is the Only PRO to Submit a Program Plan at the Deadline.
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On or Before July 1, 2025
Program Begins.
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September 1, 2025
PROs Remit First Administrative Fees to DEQ.
State Rulemaking Updates
Phase #1 Rulemaking
DEQ formed a rulemaking advisory committee (RAC) in 2022 to inform the first phase of rulemaking concepts. The RAC finished meeting in April of 2023, after which DEQ published draft rules on May 25, 2023, for public comment by July 28, 2023. The final draft rules were then submitted to the Environmental Quality Commission in November 2023. The Commission approved the rules as submitted on November 16 and 17, which have subsequently been approved by the Oregon Secretary of State. CAA provided extensive comments to DEQ throughout the rulemaking process and will continue to engage with and inform the Phase II rulemaking process through 2024.
Phase #2 Rulemaking
In the summer of 2023, DEQ began the second phase of rulemaking and established a new rulemaking advisory committee. CAA was appointed to this rulemaking advisory committee. Phase Two of the rulemaking process is underway, and CAA anticipates the Oregon DEQ will publish final draft rules in June 2024. After DEQ publishes the draft rules there will be a period for public comment before being submitted to the Environmental Quality Commission for promulgation in November. CAA encourages all producers to monitor and submit comments to DEQ as part of the second period of rulemaking.
Please visit DEQ’s website for more information.
Technical Working Groups
DEQ formed and hosted two different technical workgroups – the first focused on the list of materials that should be accepted for recycling in Oregon. The second technical workgroup, which CAA participated in, met from December 2022 to January 2024 to discuss issues related to commingled recycling processing facilities (CRPF) in Oregon for input into Phase II rules. More information on the CRPF Technical Working Group can be found of DEQ’s website.
Oregon Recycling System Advisory Council
Under the Plastic Pollution and Recycling Modernization Act, DEQ is required to convene an Advisory Council to consult with DEQ on the development of rules and the implementation of SB 582. For more information on the Oregon Recycling System Advisory Council, please visit DEQ’s Oregon Recycling System Advisory Council landing page.
Local Government Resources
The local government and service provider engagement process that takes place from May to August 2024 is a critical step for both CAA and for local governments. Data generated from the Oregon Recycling System Optimization Project (ORSOP) will enable CAA to finalize its RMA implementation plan and will prepare local governments for what RMA implementation will look like for their community. CAA contracted with Resource Recycling Systems (RRS) on this project, and RRS will conduct the formal engagement phase of the ORSOP, connecting with local governments and service providers to gather the necessary data.
The resource documents below are for internal discussion and planning purposes only. These tools are designed to help local governments and their service providers identify the information they will need to most effectively respond during the formal engagement process that will be managed by RRS. Each is downloadable as a .pdf document.
ORSOP FAQ
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The Oregon Recycling System Optimization Project (ORSOP) is a data-gathering project to inform an RMA program funding plan that CAA, as the PRO, is obligated to develop. The ORSOP effort will inform development of the recycling system expansion funding strategy, transportation reimbursement models, and framing out the PRO collection strategy across the state.
The local government and service provider engagement process that is taking place May through August of 2024, is a critical step for both CAA and for local governments. Data generated from this project will enable CAA to finalize its RMA implementation plan and will prepare local governments for what RMA implementation will look like for their community. CAA has contracted with Resource Recycling Systems (RRS) on this project, and RRS will conduct the formal engagement phase of the ORSOP effort, connecting with local governments and service providers to gather the necessary data.
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Local governments in Oregon, their service providers, and permitted solid waste facilities. If you are not an entity that is part of the shared responsibility of directly managing covered product material for recycling within Oregon, then no action is needed on your part, and you do NOT need to complete the ORSOP resource documents below.
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The suite of resources developed by the CAA team are for internal discussion and planning purposes only. These tools are designed to help local governments and their service providers identify the information they will need to most effectively respond during the formal ORSOP engagement process that will be managed by RRS. The better prepared that local governments are to respond to RRS, the more effectively that community and their haulers will be able to state their system expansion needs as well as their desire to participate in the collection of materials that will be managed by the PRO.
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The ORSOP process officially kicked off in May 2024. The local government and service provider engagement piece that is being led by the RRS team will take place from mid-May through early August. Information about the engagement process and timeline will be posted soon.
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Oregon’s EPR system is a shared responsibility model. RMA success depends on all the stakeholders collaborating in designing the system. Local government and service provider engagement is critically important at this stage, as the data generated from this project is necessary for implementing EPR in Oregon. The information gathered during the ORSOP effort will:
Enable CAA to develop the schedule of investments that will support system expansion needs at the local level related to the management of new materials collected under the Uniform Statewide Collection List (USCL);
Establish the framework of collection and depot networks across the state for managing the products that the PRO will be responsible for recycling; and
Develop transportation reimbursement models.
If local governments do not participate, their system expansion needs will not be definable, which could cause delay in negotiations to schedule any needed investments.
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CAA and RRS encourage local governments and their service providers to become familiar with the RMA, the type of expenses that will be eligible for system expansion reimbursement, and the type of supporting information that will be needed when those requests are made.
Learn more about the Recycling Modernization Act's impact on local governments on DEQ's website and watch this webinar from March 2024.
Review the ORSOP background documents and worksheets. Determine which worksheets are relevant for our community to review. Begin gathering and organizing information based on the services and needs of your jurisdiction.
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Oregon DEQ commissioned a Needs Assessment in 2023 which asked local governments to indicate their interest in expanding recycling collection opportunities in their communities. This study was conducted before the Accepted Material Lists were developed, meaning stakeholders were not able to meaningfully identify needs.
CAA needs to ensure funding requests and investments are “right-sized” to the anticipated volumes in the system. To that end, the ORSOP effort will:
Take a wasteshed approach to the discussions with local governments, considering where broader system efficiencies can be achieved on that scale,
Understand unique conditions that may exist in each jurisdiction,
Confirm the current infrastructure in place,
Identify current gaps and the associated need to determine funding prioritization set forth by DEQ,
Confirm which permitted facilities and existing LG facilities would like to participate in the PRO depot network
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To prepare local governments and their service providers for engagement with the RRS team from May through July 2024, CAA developed a suite of resources for local governments. These tools are designed for preliminary planning purposes only. The background document and worksheets will help local governments gather the information needed to respond to the formal survey that will be sent out by the RRS team.
Background on the RMA and ORSOP
On-Route Collections: Existing System and Anticipated Expansion
Depot Collections: Existing System and Anticipated System Expansion
Reload Facilities: Existing System and Anticipated System Expansion
Evaluation for PRO Acceptance List Collection
Transportation Reimbursement Considerations
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If you have questions about the ORSOP resources or the engagement process over the next few months, please reach out to:
Kim Holmes, Technical Advisor for CAA or
Joel Schoening, Consultant for RRS.
