302: Reporting Workshop - June 3, 2025

302

The Producer Reporting Workshop is a monthly opportunity for producers, their legal representatives, and trade associations to learn about and discuss priority producer issues. Please do not share this content beyond the group.

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Key Messages

Oregon 

The Oregon State Addendum will be issued out this week and next. Primary contacts will be notified once that DocuSign is sent to Authorized Representatives for signature. Please review the Oregon State Addendum and have your Authorized Representatives sign so data can be added into the Reporting Portal.  

To support producer readiness, CAA is offering weekly producer portal demonstration and training sessions. We have shared an Oregon 2025 Report Preparation Workbook that allows producers to simulate the reporting portal submission prior to formal submission in CAA's producer portal. The third installment of our reporting guidance, "Oregon Material Categories & Definitions," is also available and will provide additional details on definitions, examples and reporting tips for each reporting category.  

 

Colorado 

Colorado’s Plan Proposal was submitted to the Colorado Department of Public Health and Environment on February 3, 2025. The Plan Proposal is being reviewed for compliance by the CO EPR Advisory Board - https://cdphe.colorado.gov/hm/epr-program. 

The Plan Proposal builds on the Colorado Needs Assessment and incorporates extensive feedback solicited by CAA during a robust consultation process that engaged more than 2,000 representatives from Colorado businesses, producers, local governments, haulers, recycling service providers, trade associations, and non-profits.  

  • Covered materials are those that are included in the EPR program as stipulated in the Producer Responsibility Act, including packaging materials and paper products, except as specified in section 703(13)(b) of the Act. The covered materials can be broken down into 2 lists: 

    • Minimum Recyclable List – The uniform, statewide list of covered materials based on whether the covered material is readily recyclable.  

    • Additional Materials List – Covered materials not on the minimum recyclables list that may be collected in different geographic areas through curbside services, drop-off centers, or other means. 

    • The full list of proposed reporting categories can be found in Table 33: Covered Materials Reporting Categories of the Plan Proposal. 

    Circular Action Alliance (CAA) is working closely with Colorado Department of Public Health & Environment (CDPHE) to align on reporting categories in time for the first reporting deadline of July 31, 2025 for Colorado.  

    Separable/ Non-separable - If the components are not made of the same material but cannot be separated, then it should be reported in the category representing the material type that makes up the majority of their combined weight.  

    EPR and Bottle Bill - In states like OR that have a deposit return scheme or DRS, you do not report those items on deposit in your report to CAA. Those items are excluded from reporting.  

 

Q&A Overview

  • Producer Services is committed to replying to inquiries within 5 business days. If you have not received your credentials after you signed your PPA, please reach out to producer.support@circularaction.org and we will work to approve your PPA and provide you with your credentials soon.  

  • The answer to this question is unique per reporting state. For more information, review the definitions and examples within the Covered Materials & Producer Definitions document starting on pages 7, 33 and 43.  

    Colorado: Colorado does not require obligated producers to report on packaging weight from tertiary or third-party logistics companies. “Packaging waste will not be considered covered material if it is from a product used exclusively for professionals, industries, schools, or institutions. In this context, non-covered materials include those: 

    • Used solely in transportation or distribution to non-consumers 

    • Used solely in business-to-business transactions where the covered material is not intended to be distributed to the end consumer 

    • Not sold or distributed to covered entities 

    • Described as exempt in the Operations Plan: Material Strategy Chapter” - Colorado Program Plan pg 155 

    Additional information on this can be found in the Colorado Program Plan

  • From “Preparing your Supply Data” there are two reporting methodologies, the Specific Material Reporting Method (SMRM) and the Average Bill of Materials (ABOM).  

    You can use two different reporting methodologies as found in “Preparing your Supply Data” (Page 10). However, it’s imperative that you clearly articulate the methodologies when uploading the report. Join the 201 Producer Portal Training to learn how to do that in the tool. 

  • Yes, it can. In fact, if you did sign at the parent level, we plan to send you the state addendum at the parent level. Please ensure only the entities obligated in Oregon are represented on the state addendum. 

  • The Oregon State Addendum was issued in early February. You cannot submit your Oregon reporting data until the Oregon State Addendum is signed. Your Authorized Representative will receive the Oregon State Addendum via email from DocuSign, just like the Producer Participant Agreement (PPA) from the same domain the PPA came from: @docusign.circularaction.org. Please review the Oregon State Addendum and have your Authorized Representatives sign so data can be added into the Reporting Portal. 

 

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302: Reporting Workshop - June 17, 2025

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302: Reporting Workshop - February 18, 2025