Producer Working Group Meeting #5
The Producer Working Group (PWG) 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.
March 19, 2024
Presentation
Key Takeaways
Producer Registration with CAA. CAA has developed a formal registration form. Producers that believe they are likely to have obligations in California, Oregon, or Colorado are required to register with CAA by July 1, 2024. For more information, please visit CAA’s Producer Registration Page.
CAA’s Preliminary Reporting Categories. As required by state law, CAA has developed preliminary reporting categories which will be included in CAA’s program plan submitted on April 1, 2024. There are 62 preliminary reporting categories. CAA worked to align these categories with the 98 Covered Material Categories (CMCs) in California to the best extent possible. If approved, Oregon reporting categories and California’s final CMCs (finalized by July 1, 2024) will inform CAA’s reporting approach. The reporting categories for Oregon can be viewed in the appendix of the above PWG presentation.
CAA’s Preliminary Oregon Budget. CAA’s initial program plan will include a preliminary budget across 12 cost centers. The budget is subject to change throughout the program plan approval process as more data and information become available over the next six months.
CAA’s Preliminary Fee Schedule. As required by state law, CAA developed a preliminary fee schedule which will be included in CAA’s program plan submitted on April 1, 2024. This will not be the final fee schedule that will be the basis for producer fee invoicing and producers are encouraged to not use this fee schedule for budgeting purposes as it will change over the next six months.
The fee schedule will ultimately reflect the 62 categories and will be refined through the program development process over the next six months. The final fee schedule will be available in 2025 as producer reporting approaches.
Top Producer Questions
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While rulemaking processes are still taking place across all states there are some ways producers can begin to get prepared.
First, make sure to register with CAA by July 1, 2024.
Start reviewing California’s 98 CMCs and see how your packaging portfolio fits into the categories. CAA does not expect the list to change significantly prior to the July 1, 2024, deadline for CMC promulgation.
Start reviewing CAA’s 62 Oregon reporting categories, available in the appendix of the Producer Working Group #5 deck.
CAA is developing a guidebook to assist producers with data preparation and reporting, which will be shared with producers later in 2024.
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While each state statute contains a definition of obligated producer, there are still areas in each state’s definition that need additional clarification before CAA can provide guidance to producers. For now, please work with your legal counsel and visit CAA’s website for information.
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As part of the submission of a program plan, CAA is required to include an annual budget and fee schedule. As discussed in the March 19 Producer Working Group webinar, additional information is needed to finalize both CAA’s budget, and the fee schedule based on that budget. A critical requirement to setting an accurate fee schedule is producer supply data. To support the fee-setting process, we will require producers to report by March 31, 2025. CAA will work to refine the fee schedule, including the submission of a new fee schedule as part of a second program plan submission in Q3 of 2024.
Given the preliminary nature of these fee estimates, CAA advises against relying on the preliminary fee schedule to budget producer’s EPR compliance costs in Oregon.