Oregon Takes Step Toward a Stronger Recycling Future Through Responsible End Markets

This blog post was written by Kim Holmes, executive director, Oregon, at Circular Action Alliance (CAA)

On Monday, Feb. 9, Circular Action Alliance Oregon submitted its program plan amendment focused on Responsible End Markets (REMs) to the Oregon Department of Environmental Quality (DEQ). This submission is an important step toward building a recycling system that minimizes the impacts on the environment and human health while supporting a stable and efficient circular economy for years to come. Once approved, this amendment will improve the REM verification process in Oregon by giving every end market a practical way to meet the Recycling Modernization Act (RMA) requirements.

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 or visiting RecyclingAct.Oregon.gov to learn more. 

With this submission, Oregon continues to lead the nation in advancing REM requirements under packaging Extended Producer Responsibility (EPR) programs. These requirements set clear expectations for where and how collected materials are processed so that recycling delivers environmental and social benefits. We are proud to help bring this vision to life through a practical verification approach that begins now and grows stronger over time.  

Why Responsible End Markets Matter 

REMs ensure that materials collected for recycling are handled in ways that uphold legal compliance, transparency, environmental performance and worker safety. They help create confidence that materials leaving Oregon sorting facilities enter recycling pathways that the public can trust. Simply put, this means Oregonians will be able to participate in recycling with the confidence of knowing their materials are being managed in a way that protects the environment and the communities in which the recycling is occurring.  

Oregon is the first state in the country to put these expectations into practice. This leadership gives us a unique opportunity to shape a system that is both credible and workable for the recycling industry while meeting the goals of the RMA. Our work with hundreds of organizations makes it clear that there is strong support for these principles. At the same time, end markets need a thoughtful and realistic path to demonstrate progress. Our amendment delivers exactly that approach. 

 A Practical Start Today and a Strong Standard for the Future 

The amendment outlines a two-step progression that begins right away. 

Step One: Immediate Verification Through a Clear and Supportive Process 

Starting now, CAA Oregon will begin verifying REMs using a structured process that includes the following elements: 

1. Self-attestation and documentation from end market entities 

2. Data and permit review and chain of custody checks 

3. A risk-based method to determine when an onsite audit is needed 

4. Technical assistance to help end markets prepare for deeper verification 

5. The possibility of using other certifications to demonstrate meeting some of the REMs requirements

6. Protection of confidential business information in a manner that still supports regulatory transparency 

This process gives end markets a practical entry point. It also provides early insight into performance and helps the system steadily move toward full alignment with REM principles. 

Step Two: Development of a Formal Independent Standard 

While the immediate verification process begins now, CAA is also investing in developing a long-term solution. Standards drive industry improvement. This has been demonstrated with fair trade, organic certifications, and industry-specific certifications that drive sustainability principles. CAA has partnered with SCS Global, an ANSI-accredited standards developer, to formally launch the development of a REM certification standard. This standard will reflect input from recycling industry experts, environmental organizations, regulators and others committed to responsible material management. 

Once finalized, this standard will: 

• Support transparency and accountability 

• Strengthen market confidence 

• Provide a consistent, harmonized approach across state programs 

• Allow third-party auditing and other certifications to use the methods developed in the standard to scale across the country

• Create a mechanism for continuous improvement across the recycling system 

• This combination of immediate action and long-term standard development is designed to serve Oregon now and in the future. 

Strengthening Recycling Markets in Oregon and Nationwide 

The amendment reflects consultations with the Oregon Recycling Council and DEQ, as well as feedback from more than 250 end markets, brokers, trade associations and other recycling system interest holders. Our phased approach maintains oversight today while meeting the needs of the recycling industry and the need to advance participation.  

REMs support a healthier environment, stronger worker protections and more stable materials markets. By taking this step today, Oregon positions itself as a national leader in advancing a more transparent and effective recycling system. 

Have Your Voice Heard 

Share your thoughts with DEQ and the Oregon Recycling System Advisory Council (ORSAC). ORSAC will review the amendment at its next meeting on March 18, 2026. Additional meetings may also take up this topic. All Council meetings are open to the public and allow time for public input. Additionally, you can share your feedback on the amendment with DEQ via email at RethinkRecycling@deq.oregon.gov and CAA Oregon at OregonInfo@circularaction.org. 

Looking Ahead 

With the submission of this amendment, CAA moves from planning into action.  Once the amendment is approved, CAA will be positioned to begin verification activities and support end markets as they move through the new process of demonstrating their operational alignment with REM principles. At the same time, we are committed to delivering a strong, credible certification standard in the years ahead. 

We appreciate the collaboration of Oregon DEQ, the ORSAC and the many organizations that contributed their expertise throughout this process. Together, we are building a stronger, more transparent and resilient recycling future for Oregon.