General FAQ

CAA compiled a list of the most frequently asked questions being asked by producers and other stakeholders, and the responses. This list will be updated regularly as new information becomes available. If you have additional questions, please fill out this form.

About CAA

For more information, visit About CAA.

  • Circular Action Alliance (CAA) is a 501(c)(3), nonprofit Producer Responsibility Organization (PRO) established by 20 companies from the food, beverage, consumer goods and retail industries to support the successful implementation of Extended Producer Responsibility (EPR) laws for paper and packaging in the U.S. CAA’s vision is to be an approved PRO in all states that have enacted EPR laws for paper and packaging to deliver harmonized best-in-class compliance services, scale innovation, and build systems that help both companies and consumers waste less and recycle more.

    To date, California, Colorado, and Maryland selected CAA to serve as the single PRO in their states. CAA was selected by CalReycle as the state’s inaugural, single PRO. CAA will help all producers of single-use packaging and plastic single-use food service ware meet the requirements of California’s EPR law and advance the state’s goals of preventing plastic pollution and building a circular economy. The Colorado Department of Public Health & Environment (CDPHE) selected CAA to help producers meet their obligations under Colorado’s EPR law. The Maryland Department of the Environment (MDE) selected CAA to represent producer interests and serve as the single nonprofit PRO on the State Producer Responsibility Advisory Council.

  • CAA has 20 founding member companies representing the food, beverage, consumer goods and retail sectors. This group of producers formed CAA in response to the passage of EPR laws in California, Colorado, Maine, and Oregon. Our members have experience participating in and leading packaging EPR programs in other parts of the world and have drawn on that experience to build a U.S., nonprofit PRO that seeks to achieve harmonization of compliance services across states and implement program plans that meet the unique needs of each state.

    The Founding Members of CAA are: Amazon; Clorox; Colgate-Palmolive; Danone North America; Ferrero; General Mills; Keurig Dr Pepper; Kraft Heinz; L’Oréal; Mars, Incorporated; Mondelēz International; Nestlé USA; Niagara Bottling, LLC; PepsiCo; Procter & Gamble; SC-Johnson; Target; The Coca-Cola Company; Unilever United States; and Walmart.

    CAA will support all producers of materials covered under EPR laws in states where CAA is approved. While each state has a different timeline and approval process, CAA is developing its program plans in collaboration with producers and other stakeholders in advance of regulatory deadlines.

    Sign up to receive news and information through CAA’s newsletter.

  • To date, California, Colorado, and Maryland selected CAA to serve as the single PRO in their states. CAA was selected by CalReycle as the state’s inaugural, single PRO. CAA will help all producers of single-use packaging and plastic single-use food service ware meet the requirements of California’s EPR law and advance the state’s goals of preventing plastic pollution and building a circular economy. The Colorado Department of Public Health & Environment (CDPHE) selected CAA to help producers meet their obligations under Colorado’s EPR law. The Maryland Department of the Environment (MDE) selected CAA to represent producer interests and serve as the single nonprofit PRO on the State Producer Responsibility Advisory Council.

    CAA intends to apply to be the PRO in other states with EPR laws for paper and packaging, with the aim of supporting producers with harmonized compliance and reporting services while implementing program plans that meet the unique needs of each state.

  • CAA is actively collaborating with producers and other stakeholders early in the process and in advance of regulatory deadlines. CAA will be seeking input from a range of stakeholders to support the Colorado needs assessment and the development of program plans in each state. Additionally, CAA will engage with stakeholders and members of the public through our role as a non-voting member of the Colorado Advisory Board, and through Oregon’s Commingled Recycling Processing Facility Technical Working Group and the Phase II Rulemaking Advisory Committee.

    CAA encourages interested organizations to sign up for our newsletter and email updates, or reach out to info@circularaction.org with a specific inquiry. Covered producers should register with CAA before the July 1, 2024 deadline.

EPR 101

  • EPR is a policy approach that requires companies (“Producers”) to fund and manage programs that ensure the paper and packaging they supply to consumers are collected and recycled responsibly. EPR shifts the responsibility for the funding of collection, recycling and end-of-life management for paper and packaging from local governments and taxpayers to the producer.

    Under EPR laws, producers pay fees that may, depending on the law, fund the costs of collection, sortation, and processing of packaging – primarily in residential waste management programs – education and outreach, infrastructure improvements, and end-market verification and development. Fee structures can incentivize producers to make packaging design choices that minimize waste and environmental impacts and improve recyclability, among other attributes.

  • Under most U.S. EPR laws for paper and packaging, a PRO is a producer-led, non-profit organization that provides producers with compliance services to help them meet their obligations. Depending on the law, PROs support producers in meeting their financial obligations under EPR laws and may have operational responsibility for managing producers’ paper and packaging after use. Generally, a PRO is responsible for developing a program plan for managing covered products, which is reviewed by a state-appointed advisory board and approved by the state regulatory agency. The program plan governs program operation and the collection and management of producer fees. PROs may also be interchangeably referred to as “Stewardship Organizations” (SOs).

    The EPR laws passed in Colorado, California, Maine, and Maryland allow for just one approved PRO at program outset, while Oregon’s law allows for multiple PROs provided supporting producers represent at least 10% of the market. CAA has been selected as the PRO in California, Colorado, and Maryland. It is the only PRO to submit a program plan in Oregon, and intends to apply to be the PRO and submit program plans in other states with EPR laws for paper and packaging. For more information about PRO requirements under each state law, visit CAA’s Colorado, California, Oregon, Maine, and Maryland state pages.

  • Each company must review the producer definition under each state’s packaging EPR law and determine whether it is a covered producer in California, Colorado, and/or Oregon.

    Please consult with your legal counsel if you are unsure and make a selection based on the information currently available. CAA is unable to provide legal advice.

    Companies will have an opportunity to amend their registrations if needed. The definition of “Producer” varies in each state's law, and you should work with your legal counsel to verify where your company may have legal obligations.

    If there is no brand owner or domestic producer responsible for a brand, then the producer may be the packaging manufacturer or the company that first imports the product and the associated packaging into the United States. In Oregon, the obligated entity for foodservice ware is the supplier.

    If you require more information, please consult with your legal counsel.

    Exemptions: Producer exemptions differ in each state’s laws. All three states have a small producer exemption and exemptions for certain materials. Please consult with your legal counsel if you are unsure whether your company will be exempt or not. CAA is unable to provide legal advice.

    Relevant Statutes:

    If Questions Remain: Please consult with your legal counsel if you are unsure if your company is covered, and make a selection based on the information currently available. CAA is unable to provide legal advice. Companies will have an opportunity to amend their registrations if needed.
    CAA is developing guidance materials to provide clarity to producers on their obligations under each state’s law, including the definition of obligated producer, materials included in the state’s program, and material data reporting requirements. This guidance will be finalized and shared with producers in 2024, as regulations are finalized. In the meantime, producers may also review CAA’s Producer Compliance Center for more information.

Producers

For more information, visit the Producer Resource Center.

  • Each company must review the producer definition under each state’s packaging EPR law and determine whether it is a covered producer in California, Colorado, and/or Oregon.

    Please consult with your legal counsel if you are unsure and make a selection based on the information currently available. CAA is unable to provide legal advice.

    Companies will have an opportunity to amend their registrations if needed. The definition of “Producer” varies in each state's law, and you should work with your legal counsel to verify where your company may have legal obligations.

    If there is no brand owner or domestic producer responsible for a brand, then the producer may be the packaging manufacturer or the company that first imports the product and the associated packaging into the United States. In Oregon, the obligated entity for foodservice ware is the supplier.

    If you require more information, please consult with your legal counsel.
    Exemptions: Producer exemptions differ in each state’s laws. All three states have a small producer exemption and exemptions for certain materials. Please consult with your legal counsel if you are unsure whether your company will be exempt or not. CAA is unable to provide legal advice.

    Relevant Statutes:

    If Questions Remain: Please consult with your legal counsel if you are unsure if your company is covered, and make a selection based on the information currently available. CAA is unable to provide legal advice. Companies will have an opportunity to amend their registrations if needed.

    CAA is developing guidance materials to provide clarity to producers on their obligations under each state’s law, including the definition of obligated producer, materials included in the state’s program, and material data reporting requirements. This guidance will be finalized and shared with producers in 2024, as regulations are finalized. In the meantime, producers may also review CAA’s Producer Compliance Center for more information.

  • 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.

  • California, Colorado, Maine, and Oregon EPR laws have different fee collection requirements and timelines. Generally, when fees are collected is up to the PRO, although Colorado requires producers to pay dues to CAA on or before January 1, 2026.

    Producers who register with CAA will be updated about data reporting and fee payment timelines.

  • Fee schedules will depend on several factors, including but not limited to state needs assessment findings, rulemaking decisions, the scope of each state’s legislation, and approved program plans.

    Producers can stay on top of the latest fee payment information by registering with CAA. Other stakeholders can receive news and information through CAA’s newsletter and by attending CAA’s quarterly stakeholder webinars.

  • Producers who register with CAA will be notified of upcoming requirements and any requests for information or follow-up conversations with CAA.

    CAA is reaching out to national and state trade associations, business groups and Chambers of Commerce to raise awareness for the organization, regulatory processes and milestones, and producer requirements.

    CAA also hosts webinars open to all stakeholders and producers to raise awareness of developments in the regulatory processes and upcoming requirements in each state.

    CAA will share more information in the future about formal opportunities to participate in the organization, prior to registration deadlines and plan implementation.

  • Retailers may have unique obligations under EPR programs. Across states, if a retailer has private label products that use covered materials, or that are covered materials themselves (e.g. foodware), that retailer will be an obligated producer. Retailers may also work with the owners of the brands they sell to provide information about products that were sold in an EPR state. Lastly, retailers and wholesalers in California may have additional reporting requirements for covered materials that CAA is working to clarify with CalRecycle.

    Please consult with your legal counsel if you are unsure whether you are a covered producer. CAA is unable to provide legal advice.

Producer Registration

For more information, visit the Producer Registration page.

  • Covered producers must register with CAA by July 1, 2024.

  • There is no cost to register with CAA by the July 1, 2024, deadline.

  • The definition of “Producer” varies in each state law. Generally, producers of covered materials are the brand owners of the products or the packaging materials associated with the covered products that are sold, offered for sale, or distributed into the state.

    If there is no brand owner or domestic producer responsible for a brand, then the producer may be the packaging manufacturer or the company that first imports the product and the associated packaging into the United States. In Oregon, the obligated entity for foodservice ware is the supplier.

    Please consult with your legal counsel if you are unsure. CAA is unable to provide legal advice. Producer definitions may be clarified in the state regulatory processes.

  • Your company must review the producer definition under each state’s packaging EPR law and determine whether your company is a covered producer in California, Colorado, and/or Oregon.

    Please consult with your legal counsel if you are unsure and make a selection based on the information currently available. CAA is unable to provide legal advice. CAA understands that producer definitions are being clarified through rulemaking and companies will have an opportunity to amend their registrations if needed.

    CAA is developing guidance materials to provide clarity to producers on their obligations under each state’s law, including the definition of obligated producer, materials included in the state’s program, and material data reporting requirements. This guidance will be finalized and shared with producers in 2024, as regulations are finalized. In the meantime, producers may also review CAA’s Producer Compliance Center for more information.

  • Producers who complete CAA’s registration form before July 1, 2024, will be considered registered with CAA. Primary contacts will receive a confirmation email upon completing the registration form. Please save the email for your records.

  • The Covered Producer Registration Form requires the following information:

    • Confirmation the company is a covered producer based on its understanding of the legal definitions.

    • Producer’s legal business name.

    • States in which the company is likely to be considered a covered producer.

    • Primary contact’s email address and phone number. This is the individual who will receive communications from CAA, including information on upcoming requirements. CAA does not require the primary contact to hold particular qualifications, and companies may choose to appoint a new primary contact at any time.

    There is no cost to register.

  • CAA needs at least one point of contact per producer company. This is the individual who will receive communications from CAA, including information on upcoming requirements. CAA does not require the primary contact to hold particular qualifications, and companies may choose to appoint a new primary contact at any time.

    CAA requests only one registration per company. If there are additional employees who would like to receive CAA updates, they are encouraged to sign up for CAA’s monthly newsletter.

    If a parent company of one or more subsidiaries that will have obligations under the law, the parent company registration will be sufficient at this stage in the process. Individual subsidiaries do not need to submit contact information.

  • CAA’s registration form does not include brand information, or any other kind of data not explicitly referenced in the form. Brand information and packaging material types and amounts supplied into each EPR state will be collected by CAA at a later date.

    CAA will communicate about next steps with the primary contact on the producer registration form.

  • The primary contact is the individual who will receive official compliance communications from CAA, including information on upcoming requirements. CAA does not require the primary contact to hold particular qualifications, and companies may choose to appoint a new primary contact at any time.

  • Producers can switch their primary contact information as needed. Please email info@circularaction.org with your name and company, and name, title, email address, and phone number of the new contact.

  • CAA’s producer registration deadline is July 1, 2024. Companies that complete the form by that date will be considered registered and will be prepared when it is time to accept the applicable requirements of CAA’s producer responsibility program plans. In the coming months, registered producers will receive and be asked to sign participant agreements, and will receive detailed guidance on how to prepare for data reporting.

  • Producer exemptions differ in each state’s laws. All three states have a small producer exemption and exemptions for certain materials. Please consult with your legal counsel if you are unsure whether your company will be exempt or not. CAA is unable to provide legal advice.

  • If you are the parent company of one or more subsidiaries that will have obligations under the law, parent company registration will be sufficient at this stage in the process. Individual subsidiaries do not need to submit contact information.

  • No, CAA’s registration form allows producers to select multiple states where the company expects to be considered a covered producer. CAA requests only one registration per company for all states.

  • Unless a producer intends to submit its own plan in Colorado, it is required to register with CAA by July 1, 2024. Failure to register may result in the Colorado Department of Public Health and Environment (CDPHE) imposing fines.

    In all states, registration by July 1, 2024, will help ensure producers receive reporting guidance and will provide CAA with the information needed for the PRO to set accurate fees.

  • While CAA is participating in the regulatory process in Maine, the Maine Department of Environmental Protection has yet to release the Request for Proposals for prospective PROs and select a PRO. To date, CAA has been approved as the single PRO in California and Colorado and expects to be the approved PRO in Oregon once CAA’s program plan is approved.