Navigating Oregon’s Recycling Modernization Act: What Producers Need to Know
This blog post is written by Kim Holmes, Oregon Executive Director at Circular Action Alliance.
As Circular Action Alliance’s Oregon Executive Director, my goal is to ensure the successful implementation of Oregon's Extended Producer Responsibility (EPR) law, the Recycling Modernization Act (RMA). A huge piece of that is working with the Oregon Department of Environmental Quality to outline the compliance and enforcement processes that will affect producers under the RMA. As we near the pivotal March 31 reporting deadline, I'd like to shed light on the RMA's core principles and compliance mechanisms. Our collective efforts are crucial in shaping a sustainable future for Oregon, and your participation is essential in achieving its goals.
Overview of the Recycling Modernization Act
The Recycling Modernization Act is designed to transform Oregon’s recycling system, making it more efficient, equitable, and environmentally responsible. The law aims to:
Reduce waste and improve recycling rates.
Ensure producers share responsibility for managing the end-of-life of their products.
Support a more sustainable and circular economy.
By requiring producers to register and report their covered materials to CAA, the Act ensures accountability and long-term sustainability in the materials supply chain.
Who Needs to Register?
Producers, manufacturers and importers of packaging, printing and writing paper, and food serviceware must register and report to Circular Action Alliance Oregon (CAA) by March 31, 2025, to comply with the law.
Why Registration Matters for Producers
Registering with CAA offers several benefits:
Representation: CAA advocates on behalf of registered producers, ensuring their voices are heard in the implementation of the Act.
Legal Compliance: Registration ensures adherence to the law, preventing potential legal issues.
Enhanced Reputation: Being listed as a compliant producer demonstrates a strong commitment to compliance, sustainability and corporate responsibility.
Deadlines and Consequences for Non-Compliance
As DEQ recently re-emphasized in their RMA newsletter, "Producers must register with and report 2024 Oregon supply data to Circular Action Alliance by Monday, March 31, 2025." This deadline represents a pivotal moment for responsible producers. By meeting this critical date, you're not just checking a box—you're positioning your organization with other compliant producers at the forefront of Oregon's recycling innovation. CAA will monitor compliance through periodic audits; however, it’s important for producers to understand the compliance considerations:
Transparency and Reputation: Under ORS 459A.869(8), CAA is required to publish both a comprehensive list of compliant producers and a list of producers who have not met their regulatory obligations. And remember that registration alone does not equate to full compliance. While you can currently view the list of registered producers on CAA's website, this list will evolve to clearly distinguish between those who have merely registered and those who have fully reported their data later this year.
Financial Consequences: Non-compliance carries significant financial risks, including late fees and other potential damages. Producers found to be non-compliant due to inaccurate or late reporting and fee payments will be required to retroactively pay all outstanding fees for the period of non-compliance, along with applicable late charges or liquidated damages.
Escalating Enforcement: The consequences of non-compliance can escalate quickly. If CAA is unable to adequately resolve a non-compliance issue, it will be referred to the Oregon Department of Environmental Quality (DEQ) for further action. Penalties for failing to register or report can result in fines of up to $25,000 per day. In the most severe cases, the Oregon Department of Justice may intervene to halt your product sales in the state—effectively freezing your Oregon market access.
You can view the complete regulatory framework for producers, including compliance obligations, on DEQ’s website at RecyclingAct.Oregon.gov.
Steps to Register and Report
The first step to meeting your obligations under the RMA is to register with CAA. Even if you have registered, however, you still have more to do to get your report in by the March 31, 2025 deadline.
To finalize your registration, you must:
Complete the registration form in the CAA Producer Portal.
Sign the Participant Producer Agreement (PPA).
Review and sign the required State Addenda for your obligations.
Report your data into the CAA Producer Portal by March 31 for Oregon.
These steps are time-sensitive and required for you to submit your producer report. If you are unsure of your status, please contact producer.support@circularaction.org as soon as possible.
Support and Resources for Producers
We know that navigating EPR can feel like uncharted territory, especially if this is your first time. That’s why CAA created a robust toolkit to simplify your journey, ensuring your company can confidently meet your obligations:
Producer Resource Center: Access FAQs, support documents, and more.
Webinars: Join our informative webinars, including:
101 Producer Onboarding
102 Registration & Agreements
103 Budgeting for EPR Fees
Information Sessions & Education: Participate in reporting workshops and other educational sessions.
Reporting Guidance: Receive detailed guidance on reporting requirements.
Producer Portal: Utilize our online portal for easy access to resources and support.
Our Producer Services team is here to help you navigate. You can reach out to them any time at Producer.support@circularaction.org or visit the CAA Producer Resource Center.
Register Today!
It’s not too late to start the process! Ensuring compliance with the Recycling Modernization Act is not just the right thing to do. It’s a legal requirement—and a critical step toward a more sustainable Oregon. By registering with CAA, you contribute to a responsible circular economy that benefits both businesses and the environment.
We encourage all producers to act now and register today to stay ahead of the deadline in Oregon (and Colorado on July 1) and avoid penalties. Together, we can drive meaningful change and build a better future for recycling in Oregon.
Kim Holmes
Oregon Executive Director
Circular Action Alliance