Producer Working Group Meeting #12

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.

October 22, 2024

Presentation

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Key Takeaways

  1. Upcoming Producer Compliance Actions & Dates:

    o   November 8, 2024: As a parent company, if you’d like to request an exception to sign the Participant Producer Agreement (PPA) as a parent company covering multiple subsidiaries, complete an exception request by November 8, 2024. If there is no subsidiary or each subsidiary will sign the PPA separately then submitting the exception form is not required.

    o   November 11, 2024: Primary Contacts will receive a request to complete a new form to update your company’s registration with relevant and necessary information for your company and each subsidiary, if applicable. This form is required for each subsidiary even if you are requesting an exception to sign PPA at parent level. Note that you will be asked to designate an Authorized Representative with signing authority for your company in this form, in addition to a Primary Contact for day-to-day communications.

    o   Once the new information is provided and processed by CAA, the PPA will be sent to the pertinent Authorized Representative for signature.

    o   Once a PPA is signed, confidential reporting guidance will be shared with each producer.

  2. As a reminder, all producers will report material supply data to CAA at the subsidiary level once program reporting modules are available. Most producers will also sign a single PPA for each subsidiary that has its own tax ID number or EIN.

  3. CAA shared that Oregon estimated fee rate ranges were published in CAA's Program Plan #2 submitted in September 2024, and this fee schedule can be used by producers for internal budgeting for 2025 EPR fees (as OR is the only program with fee obligations in 2025). A more detailed fee schedule for all material reporting categories in Oregon is being developed now with improved estimates on system cost and material supply, and the updated fee schedule will be included in the next Program Plan #3.

Top Producer Questions

For a more Frequently Asked Questions, please visit CAA’s FAQ page.

  • The exception request is optional, but only exception requests received by November 8 will be considered. This form is only for producers who choose to sign one PPA for the parent company and all subsidiaries. The form should not be submitted by:

    • Producers who have no additional parent company or subsidiaries

    • Producers with subsidiaries who will each sign the PPA separately

  • The week of November 11, producers will be asked to provide additional information to CAA for their company, including for each subsidiary. Completing this form will allow CAA to send you the PPA via DocuSign for electronic signature. Filling out the new form in a timely manner helps CAA to send the PPA sooner.

  • The following information is required:

    • Tax ID/Employee Identification Number (EIN) - An Employer Identification Number or EIN is a Tax Identification Number for businesses that is nine digits long and assigned by the IRS

    • Company headquarter’s address

    • Company website

    • Estimated U.S. Annual Gross Revenue for your company in U.S. dollars (Provide 2023 annual U.S. revenue, or estimated 2024 number. CAA will use this information as a proxy to help determine representation of the marketplace.)

    • Tax exemption status

    • Authorized Representative name, email, phone number

  • No. All producers will sign the same version of the PPA. This creates fairness for all producers. The PPA went through a comprehensive consultation process with Producers and internal review by CAA to ensure it adequately balances the ability to meet regulatory requirements with the feedback of producers.  An explanation of key elements in the PPA was provided in PWG #11.

  • Producers are encouraged to sign the PPA in November to gain access to confidential reporting guidance to help you prepare your data for Oregon reporting, due March 31, 2025. Ultimately, producers will not be able to access the reporting module without signing the PPA.  CAA has not finalized the timing of launching the reporting module (likely in early Q1-2025 for OR), and therefore will share a PPA signing deadline in an upcoming communication. 

  • All producers will be asked to complete the updated registration form on November 11. This form will include a verification email that will confirm you have successfully registered for your company and each subsidiary. After the week of November 11, completing this new form is the best way to complete and verify your updated registration with CAA.

  • Please register for upcoming sessions on a variety of topics here, including Reporting Q&A session on November 19. Producers will be provided additional guidance upon signing the PPA. 

  • If you have links or bookmarks to the CAA website that are not working, please try using https://circularaction.org as the domain of your link, instead of https://circularactionalliance.org.

    Here are some common links helpful for producers:

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