Producer Working Group Meeting #11
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.
September 17, 2024
Presentation
Key Takeaways
Early Producer Reporting Deadlines are a Key Step in the EPR Implementation Process. There are several reasons why initial producer reporting deadlines are set before program start dates. For some states, these reporting deadlines are set in statute or in rule. Furthermore, producer data is needed to inform the development of fair and accurate fee schedules. Oregon will be the first reporting deadline for producers and is March 31, 2025. The California and Colorado reporting deadline is August 31, 2025.
There will be State Specific Addenda to the Participant Producer Agreement (PPA) Accommodating State Specific Requirements. The PPA contains the terms and conditions between CAA and participant producers. The terms and conditions outline the actions to be taken by both CAA and participant producers to ensure that statutory obligations are fulfilled under state EPR laws. This includes CAA’s obligations as a PRO, producer obligations as the regulated entity, confidentiality, and dispute resolution.
Following program plan approvals in each state, state specific addenda will be added to the PPA. These addenda will include state specific requirements and upon signing, obligate producers to pay fees to CAA for compliance in that state.
The PPA is a Nonbinding Agreement. If a producer later determines that it is not covered under a state’s EPR program or prefers to fulfill its obligations independently as state law may allow, it can terminate the agreement at any time.
A Summary of the Consultation Feedback will be Distributed. Following the PPA Consultation, CAA will share a summary of the feedback collected alongside the final version of the PPA. CAA anticipates releasing the final version of the PPA by the end of October 2024.
Top Producer Questions
For a more Frequently Asked Questions, please visit CAA’s FAQ page.
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CAA anticipates releasing a finalized version of the PPA by the end of October 2024. The Oregon state addendum will be released in early Q1 2025 and must be signed prior to submitting data in March 2025. The PPA must be signed in order to access CAA’s reporting guidance and portal. CAA anticipates releasing additional state addenda after program plan approvals in each state.
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Both the primary contact and the authorized representative will have access to CAA’s portal.
Primary Contact: This person will be the first point of contact for communications with Circular Action Alliance (CAA). This will be the individual notified of upcoming requirements and any requests for information or follow-up conversations with CAA. This will enable CAA to notify your company when it is time to accept the applicable requirements of CAA’s producer responsibility program plans
Authorized Representative: This person is authorized on behalf of the producer to bind the company, sign legal contracts, and submit material supply data to CAA.
Reporting Contact: There will also be a third seat for your organization that will have access to the portal, upon request. This seat could be filled by an internal member of your team or a third-party that your organization is working with on reporting. This seat will be able to upload data to the portal but will not be able to submit the final data report.
To provide an authorized user and/or update a primary contact, complete this form.
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No. There is no additional information required from registered producers to meet the Colorado producer registration deadline. Subsidiaries of parent companies registered with CAA are considered registered producers and are compliant with Colorado’s producer registration deadline.
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Additional guidance on covered materials and the definition of producer will be made available on CAA’s website in the coming weeks. Detailed reporting guidance will be available to registered producers after they sign the PPA. CAA anticipates releasing a finalized version of the PPA by the end of October 2024.
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CAA is developing a national fee setting methodology that will guide the creation of fee schedules for each state. A general overview of fee setting was shared during PWG Meeting #3 and a deeper dive into CAA’s fee setting process, including CAA’s national guiding principles on fee setting, occurred at PWG Meeting #10.
State addenda will include more details on specific regulatory requirements that affect fee setting in the state. Finalized state fee schedules (i.e. fee rates) will be released after initial producer reporting has been completed. CAA requires producer data in order to set accurate and fair producer fees. A preliminary fee schedule for Oregon will be included in CAA’s program plan, being submitted to Oregon DEQ by September 27, 2024.