Producer Working Group Meeting #14
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.
December 17, 2024
Presentation
Key Takeaways
California Draft Regulation Feedback
CAA provided feedback on the draft regulation to CalRecycle on December 17, 2024. CAA made the following recommendations:
Clarifying the producer definition as it relates to food serviceware.
CAA highlighted that CalRecycle moved the deadline for the submission of the PRO Annual Report to July 1 from April 1 (CAA advocated for this in the first and second drafts)
CAA also recommends that all producers shall become a participant of an approved PRO or apply to be an Independent Producer by April 1, 2025, to ensure producers register and can begin reporting.
CAA also recommends the regulation allows CAA to collaborate with local jurisdictions and recycling service providers to develop a dispute resolution process that can be applied equally and fairly to all participants in the reimbursement process.
Oregon Program Plan 3 Update
CAA submitted the third program plan to the Oregon Department of Environmental Quality (DEQ) on December 6, 2024. Program Plan 3 included updates to the collection & recycling of Uniform Statewide Collection List (USCL) materials, PRO recycling acceptance list, and a more detailed list of material reporting categories and fee schedule. The CAA Oregon team is now actively working to be ready for the July 1, 2025, program start date.
CAA worked with the Recycled Materials Standard (RMS) to develop a material-neutral audit protocol for responsible end markets (REM) verifications and is forming a REMs workgroup to begin field testing the audit protocol. CAA aims to verify up to 25 REMs in 2025.
Eco-modulation is a graduated fee structure that encourages producers to make continual reductions in the environmental and human health impacts of covered materials. In Oregon, eco-modulation includes three bonuses:
Bonus A: Producers that perform an LCA and disclose on up to 10 stockkeeping units, or SKUs, following DEQ’s LCA standards. CAA will set Bonus A at 10% of base fees, capped at $20,000 for each SKU or batch of SKUs.
Bonus B: Provided to producers that conduct an LCA on primary packaging material that demonstrates significant impact reductions through packaging change performed on a SKU or batch of SKUs. Bonus B is based on three impact tiers:
Tier 1: impact reduction of 10-25%
Tier 2: impact reduction of greater than 25-40%
Tier 3: impact reduction of greater than 40%
Bonus C: CAA will develop a third bonus to reward producers for moving toward reuse of covered products.
Local government funding for system expansion will be prioritized based on population size and system needs.
The CAA team is laying the groundwork for launching the PRO collection network in 2025
Education & outreach branding has been selected, and the first batch of beta materials will be available beginning in Q1 of 2025.
Producer Services Update
Upcoming compliance deadlines:
December 31, 2024 – CAA encourages producers to submit signed Participant Producer Agreement to ensure access to the Producer Portal in January 2025
March 31, 2025 – Oregon producer reporting deadline
July 1, 2025 – Oregon program starts and fees begin
August 31, 2025 – California and Colorado producer reporting deadlines (proposed)
2024 producer events have received positive feedback, with 82% of survey respondents indicating they are mostly or very satisfied with the producer events and 76% responding that they find CAA mostly or very effective at preparing producers for EPR compliance.
The CAA team is laying the groundwork for launching the PRO collection network in 2025
The team has new events planned for 2025. Sign up for upcoming producer educational webinars, including producer portal trainings and reporting workshops, on our website.
Top Producer Questions
For a more Frequently Asked Questions, please visit CAA’s FAQ page.
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The PPA was sent to the authorized representative and may have gotten blocked by your spam filters. Please contact your IT security team and ask them to whitelist inbound email traffic from the domain (docusign.circularaction.org) to avoid delays in communication or disruption with CAA DocuSign execution of agreements. If you have done this and still have not received it, email producer.support@circularaction.org and someone should get back to you as soon as possible. Right now, due to higher than normal questions, the response time is about 7 days. CAA is working to improve this significantly in 2025.
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You should have received a link to the guidance after signing the Participants Producer Agreement (PPA).
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In late January 2025.
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It’s called the “pre-registration” rule in DEQ’s rules to distinguish that it’s only a data reporting deadline rather than the deadline upon which producer fee payment begins. Find more information in the Oregon Administrative Rule (OAR) 340-090-0870.
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Eco-modulation applies to all covered products not just those on the USCL or PRO acceptance lists. Find more information on eco-modulation in Program Plan 3 starting on page 209.
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More information on reporting categories can be found on page 190 in Program Plan 3. Draft Base Fee Rate Estimates begin on page 198.
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Guidance on LCAs can be found in OAR 340-090-0900 through 0930.
