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 U.S. Producer Responsibility Organization (PRO) dedicated to implementing effective Extended Producer Responsibility (EPR) laws for paper and packaging. As a nonprofit, producer-led organization, CAA is committed to delivering harmonized, best-in-class compliance services to all producers to advance an efficient and effective circular economy. CAA was founded in 2022 by 20 producers representing the food, beverage, consumer goods, and retail industries.
CAA is the only organization approved to implement U.S. EPR laws for paper and packaging, and is operating as the single PRO in California, Colorado and Minnesota. CAA has submitted an initial program plan to operate as the PRO in Oregon, and has also been selected to represent producer interests and the PRO on the State Producer Responsibility Advisory Council in Maryland.
The organization was founded and is governed by 20 producers representing the food, beverage, consumer goods, and retail industries. The Board of Directors supports CAA’s CEO, Jeff Fielkow, by providing strategic oversight of the development and implementation of EPR programs.
To date, California, Colorado, Minnesota 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 Minnesota Pollution Control Agency confirmed CAA’s registration to implement the state’s EPR program. 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.
To comply with producer registration requirements under California, Colorado, Oregon and Minnesota EPR laws for paper and packaging products, covered producers must register with CAA unless the producer qualifies for an exemption or the producer intends to submit an individual compliance plan, under applicable law.
Only registered producers will gain access to CAA’s producer education forums, such as monthly producer working group meetings, data reporting preparation sessions, and a producer guidebook that will include detailed information on reporting and fees.
CAA is also actively collaborating with producers, service providers, local governments and communities to advance and inform the implementation of EPR programs for paper and packaging. CAA will be holding consultation sessions to inform the program planning process in each state. Additionally, CAA engages with members of the public through our participation in state Advisory Board meetings and in our capacity as a non-voting member of those Boards.
CAA encourages interested organizations to sign up for our newsletter and email updates, or reach out to info@circularaction.org with a specific inquiry. You can also visit each state page to learn more about how to get involved with their program.
We ask that producers reach out to producer.support@circularaction.org for assistance on questions surrounding producer obligations.

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, Minnesota 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, Minnesota 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, Minnesota 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. CAA is not able to provide legal advice or make this determination for you.
However, CAA has developed guidance to help businesses answer the two primary questions they need to ask that will help determine if they are obligated under the EPR laws:
1. Is the material associated with my products covered by the EPR laws?
1. Is my business the responsible producer for those materials?
Please review CAA’s guidance materials for further information.
Please note that CAA guidance is not meant to constitute legal advice, and CAA assumes no responsibility for the decisions made by producers in determining their obligations. CAA suggests that producers work with their attorneys to review the relevant statutes, rules and regulations to determine their responsibilities.
Relevant Statutes:

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. CAA is not able to provide legal advice or make this determination for you.
However, CAA has developed guidance to help businesses answer the two primary questions they need to ask that will help determine if they are obligated under the EPR laws:
1. Is the material associated with my products covered by the EPR laws?
1. Is my business the responsible producer for those materials?
Please review CAA’s guidance materials for further information.
Please note that CAA guidance is not meant to constitute legal advice, and CAA assumes no responsibility for the decisions made by producers in determining their obligations. CAA suggests that producers work with their attorneys to review the relevant statutes, rules and regulations to determine their responsibilities.
Relevant Statutes:
To comply with producer registration requirements under California, Colorado, and Oregon EPR laws for paper and packaging products, covered producers must register with CAA unless the producer qualifies for an exemption or the producer intends to submit an individual compliance plan, under applicable law.
Regulations in Colorado required producers to register by October 1, 2024. Producers who did not register by that date may be subject to enforcement. CAA has submitted a list of registered producers to the Colorado Department of Public Health & Environment (CDPHE) following the October deadline and will be sharing updated lists as required.
CAA has provided the Oregon Department of Environmental Quality (DEQ) with a list of registered producers as part of CAA’s revised program plan, submissions and will continue to provide updated lists as required.
Producers in these states who missed the deadline need to still register with CAA, sign our Participant Producer Agreement and any relevant state addendum.
Only registered producers will gain access to CAA’s producer reporting portal and educational materials and forums to support the producer compliance journey.
California, Colorado, Maine, and Oregon EPR laws have different fee collection requirements and timelines. Oregon will be the first state where producers have fee obligations when the program begins on July 1, 2025. Fee obligations in Colorado will begin in January 2026. In California, fee obligations start in January 2027.
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.
In Oregon, the first state to require producers to pay fees, CAA has provided interim base fee estimates for three scenarios in its September program plan submission. In the December 2024 program plan submission, CAA shares a more granular estimate.
Please join a Budgeting for EPR Fees onboarding session to learn more.
Producers can stay on top of the latest fee payment information by registering with CAA and gaining access to our producer services events and communications.
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.
- 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.
- 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.
- Yes, you should register.
- You should report on the materials that are covered, and you should exclude the non-covered products and packaging in your reported weights.
- There are multiple components to producer fees. Base fees, eco-modulated fees & CAA’s approach to assigning fair fees.
- Base fees almost always vary by packaging type. The variation reflects the differences between each material in terms of (but not limited to) its quantities, cost to recycle, revenues, and recycling performance.
- Eco-modulated fees vary between producers. They are adjustments made to fees in the form of incentives (“bonuses”) or disincentives (“maluses”) that drive at targeted policy outcomes beyond the factors accounted for in base fees e.g. the use of bio-based materials or recycled content.
- To fairly set fees for producers, PROs require:
  - Guiding principles
  - A fee-setting methodology
  - Significant data and modeling
- The goal is to ensure each producer contributes its fair share of fees to the program based on the type and quantity of materials it supplies and their impacts.

Producer Registration

For more information, visit the Producer Registration page.

To comply with producer registration requirements under California, Colorado, and Oregon EPR laws for paper and packaging products, covered producers must register with CAA unless the producer qualifies for an exemption or the producer intends to submit an individual compliance plan, under applicable law.
Regulations in Colorado required producers to register by October 1, 2024. Producers who did not register by that date may be subject to enforcement. CAA will be submitting a list of registered producers to the Colorado Department of Public Health & Environment following the October deadline. CAA will be submitting a list of registered producers to the Colorado Department of Public Health & Environment as required.
CAA was required to provide the Oregon DEQ with a list of registered producers as part of CAA’s revised program plan, submitted on September 27, 2024.
Producers in these states who missed the deadline need to still register with CAA.
Only registered producers will gain access to CAA’s producer education forums, such as the Producer Working Group (PWG), and receive detailed guidance to support data preparation and reporting.
To comply with producer registration requirements under California, Colorado, and Oregon EPR laws for paper and packaging products, covered producers must register with CAA unless the producer qualifies for an exemption or the producer intends to submit an individual compliance plan, under applicable law.
Regulations in Colorado required producers to register by October 1, 2024. Producers who did not register by that date may be subject to enforcement. CAA will be submitting a list of registered producers to the Colorado Department of Public Health & Environment following the October deadline. CAA will be submitting a list of registered producers to the Colorado Department of Public Health & Environment as required.
CAA was required to provide the Oregon DEQ with a list of registered producers as part of CAA’s revised program plan, submitted on September 27, 2024.
Producers in these states who missed the deadline need to still register with CAA.
Only registered producers will gain access to CAA’s producer education forums, such as the Producer Working Group (PWG), and receive detailed guidance to support data preparation and reporting.
There is no cost to register with CAA.
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. CAA is not able to provide legal advice or make this determination for you.
However, CAA has developed guidance to help businesses answer the two primary questions they need to ask that will help determine if they are obligated under the EPR laws:
1. Is the material associated with my products covered by the EPR laws?
1. Is my business the responsible producer for those materials?
Please review CAA’s guidance materials for further information.
Please note that CAA guidance is not meant to constitute legal advice, and CAA assumes no responsibility for the decisions made by producers in determining their obligations. CAA suggests that producers work with their attorneys to review the relevant statutes, rules and regulations to determine their responsibilities.
Relevant Statutes:
Producers who complete CAA’s registration form 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 an obligated producer based on its understanding of the legal definitions.
- Producer’s legal business name.
- EIN number associated with your company.
- Company name and EIN number associated with your parent company.
- States in which the company is likely to be considered an obligated producer.
- Contact information, specifically:
  - Primary Contact: This person will be the first point of contact for communications with CAA. This will be the individual who will be notified of upcoming requirements and any requests for information or follow-up conversations with CAA. This will enable CAA to notify your company when it is time to accept the applicable requirements of CAA’s producer responsibility
  - Authorized Representative: This person is authorized on behalf of the producer to bind the company, sign legal contracts and submit material supply data to CAA.
There is no cost to register.
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.
Producers can switch their primary contact information as needed. Please email Producer.Support@circularaction.org with your name and company, and name, title, email address, and phone number of the new contact.
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.
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.
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.
CAA is preparing documentation to register with the Commissioner of the Minnesota Pollution Control Agency (MPCA) by January 1, 2025, and is not yet able to accept producer registrations for Minnesota. Producers must be a member of a PRO that is registered with MPCA by July 1, 2025.
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.