Producer Working Group Meeting #10
The Producer Working Group (PWG) is a monthly opportunity for registered producers, their legal representatives, and trade associations to learn about and discuss priority producer issues. Please do not share this content beyond the group.
August 22, 2024
Presentation
Key Takeaways
CAA is preparing for a Q4 launch target of its reporting portal. CAA provided a preview demonstration of the producer reporting portal currently in development. The new tool will include a Producer Registration form, a reporting questionnaire to help producers determine if they are covered and if so, in which states, and step-by-step process to input or upload data. The portal will also ask for additional information such as a producer’s subsidiaries and methodology for calculating its data.
State timelines through 2028 were shared for California, Colorado and Oregon. CAA shared what producers should be planning for over the next four years based on administrative and regulatory deadlines in California, Colorado, and Oregon. Deadlines include the release of annual fee schedules, invoice dates, and annual reporting deadlines. These timelines are preliminary and may be updated as needed (any updates will be communicated to producers).
Fee methodology and eco-modulation comparison across states. CAA shared a high-level view of CAA’s fee modeling approach, including the guiding principles adopted by CAA in the fee-setting process. Following the review of the fee setting methodology, CAA shared a cross-state comparison of eco-modulation and how eco-modulation factors into fee-setting. A deeper dive into eco-modulation will take place at a future PWG meeting as key elements of the requirements are developed.
Top Producer Questions
For a more Frequently Asked Questions, please visit CAA’s FAQ page.
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CAA is currently finalizing the PPA, which will be shared with producers once ready. The PPA will provide the legal foundation for CAA’s compliance services, including confidentiality and the rights and obligations of all parties. The purpose of the PPA is to facilitate additional training and compliance steps for each producer, allowing timely preparation ahead of imminent reporting deadlines across the EPR states.
In addition to the general clauses in the PPA, CAA will develop state addenda to the PPA that will address specific state requirements. Until a producer has signed a state addendum, the producer will not be formally considered an obligated producer in any state and will therefore have no reporting, fee, or other obligations under a state EPR statute.
Producers will have to sign both the primary agreement and each appropriate state addendum before being able to submit data. The producer signatory of the PPA must be an employee of the company and have signing authority.
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CAA’s producer portal and in-depth producer guidance will only be available to producers that have signed the PPA. State addendum will not be required to access the producer portal or in-depth guidance.
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More guidance will be provided by CAA. However, producers with EINs should plan to input data. The portal will also include a space for parent companies to list all subsidiaries and/or brands.
CAA intends to allow multiple portal credentials per company. Each company will only have one account that will allow that company to report across states, as relevant.
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Yes, if a producer registers and signs the PPA and later determines it does not have any obligations, the producer can cancel its registration.
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There will be an Excel template that will be available allowing users to upload data. CAA will provide additional guidance to producers about the data upload and management process closer to launch of the portal.
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Oregon is the first state that will require data reporting, with a deadline of March 31, 2025. The required data period will be calendar year 2024. CAA recognizes that many producers may not have access to an entire calendar years’ worth of data. CAA will provide additional guidance on data estimation and an estimation methodology as part of the reporting guidance that will be released to producers that sign the PPA.