CAA Oregon Submits Updated Responsible End Market Amendment to Strengthen Recycling Verification
Mar. 9, 2026 — On Monday, Feb. 9, Circular Action Alliance (CAA) Oregon submitted an updated Responsible End Market (REM) program plan amendment to the Oregon Department of Environmental Quality (DEQ), advancing implementation of Oregon’s Recycling Modernization Act by strengthening how recyclable materials are verified as responsibly recycled – a cornerstone of the Recycling Modernization Act.
The amendment strikes the right balance of achieving the regulatory and statutory requirements while also offering a practical starting point for engaging and educating the recycling industry on new requirements. This approach allows end market verification to begin immediately within the system, while work continues on a formal, harmonized REM certification standard intended for broad adoption across U.S. packaging extended producer responsibility (EPR) programs.
“Oregon has been a national leader in defining Responsible End Markets, and this amendment strengthens that leadership with a practical approach we can implement right away,” said Jeff Fielkow, Chief Executive Officer of Circular Action Alliance. “By advancing a solution that is both rigorous and workable for end markets, we’re establishing a harmonized system that fully supports Oregon’s priorities while building a framework that producers, processors and recyclers can rely on over the long term.”
Why this matters
The submission strengthens Oregon’s interim verification approach and supports the development of a comprehensive, auditable standard for eventual consideration by the Environmental Quality Commission (EQC). This approach enables near-term accountability while laying the foundation for a permanent, consistent REM standard that can be scaled nationally.
Key highlights of the amendment
Affirms REM principles. The amendment is designed to meet the REM requirements of transparency, compliance, environmental soundness and adequate yields. CAA remains committed to a practical, enforceable standard that protects proprietary information and helps maintain market stability.
Interim pathway, then formal standard. The amendment creates an interim verification pathway until a formal third-party standard is developed with an ANSI-accredited standards developer and considered by the EQC.
Built for Oregon, with a path to national harmonization. The verification approach meets Oregon’s regulatory requirements and is structured to support consistent REM verification across packaging EPR states, advancing a harmonized national framework. CAA’s long-term vision is a standard that meets Oregon’s requirements and those of other EPR states.
One of the most comprehensive assessments to date. Based on CAA’s review of existing EPR verification practices, the proposed approach is among the most comprehensive end market assessments across jurisdictions with packaging EPR, in some areas exceeding current verification practices in the EU and Canada.
“Oregon led by putting Responsible End Markets into law, and this amendment moves that work forward in a way that meets the spirit of the law and will bring assurance to Oregonians that their participation in recycling is not causing undue burden to the environment and other communities,” said Kim Holmes, Executive Director of CAA Oregon. “Our goal is to develop a robust system that upholds Oregon’s requirements and gives end markets confidence to participate at scale.”
What’s Next
DEQ and the Oregon Recycling System Advisory Council (ORSAC) will review the amendment and provide approval, conditional approval or send it back to CAA for additional work. If sent back, CAA will have a final opportunity to submit a third version of the amendment, which DEQ can accept or direct binding changes. While the process advances, CAA will continue working with end markets and other interested parties.
As DEQ reviews the amendment, interested parties have an opportunity to help shape the future of their recycling system. The DEQ public comment period is open from Feb. 23, 2026, through Mar. 27, 2026. We encourage all interest holders to share their feedback to advance strong, transparent, and accountable REM standards by attending an Oregon Recycling Council Meeting and emailing DEQ at RethinkRecycling@deq.oregon.gov. Visit RecyclingAct.Oregon.gov to learn more.
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About Circular Action Alliance
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 helping producers comply with EPR laws, delivering harmonized best-in-class compliance services and to working with governments, businesses and communities to reduce waste and recycle more. CAA was founded in 2022 and is led by producers representing the food, beverage, consumer goods, and retail industries.
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