Producer Registration

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To comply with California, Colorado, Oregon, and Minnesota EPR laws for paper and packaging, obligated producers must register with CAA as required under applicable law. Only registered producers will gain access to CAA’s registered producer resources, including the 300 and 400 series producer events, and producer guidance that will include detailed information on producer supply reporting and fees.

How to Register

Producers begin registration by completing CAA’s Account Registration Form. This form needs to be completed once for each subsidiary company, based on EIN (Employer Identification Number). The form requires the following information:

  • Confirmation the company is an obligated producer based on its understanding of the legal definitions.

  • Producer’s legal business name.

  • EIN number associated with your company.

  • Company name and EIN number associated with your parent company.

  • States in which the company is likely to be considered an obligated producer.

Contact information, specifically:

  • Primary Contact: This person will be the first point of contact for communications with CAA. This will be the individual who will be 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 and has the ability to submit material supply data to CAA.

  • Authorized Representative: This person is authorized on behalf of the producer to bind the company, sign legal contracts and has the ability to submit material supply data to CAA.

Producer Registration Lists

Certain programs require CAA to publish a list of registered producers. Those lists are available publicly, and the date of publication appears on each list.

CAA was required to provide the Oregon DEQ with a list of registered producers as part of CAA’s revised program plan, submitted on September 27, 2024 and has been regularly updated. CAA was asked to provide a list of non-reporting producers to the Oregon Department of Environmental Quality (DEQ) so that they can follow-up with producers about their obligations under the Recycling Modernization Act, including the requirement to submit reports and pay fees starting on July 1, 2025.

Regulations in Colorado required producers to register by October 1, 2024. Producers who did not register by that date may be subject to enforcement. CAA also submitting a list of registered producers to the Colorado Department of Public Health & Environment as required. Producers in those states who missed the deadline must still register with CAA.

Determining Producer Obligations Under EPR Laws

There are two primary questions businesses need to ask that will help determine if they are obligated under the EPR laws:

  1. Is the material associated with my products covered by the EPR laws?

  2. Is my business the responsible producer for those materials?

CAA has released guidance to help producers answer these questions for Oregon and Colorado. Producers with obligations in Colorado were required to register with CAA by October 1, 2024. Producers with obligations in Oregon should have submitted their first supply report by March 31, 2025, and had to be registered with CAA and have signed both a PPA and State Addenda in order to do so.

Please note that CAA guidance is not meant to constitute legal advice, and CAA assumes no responsibility for the decisions made by producers in determining their obligations. CAA suggests that producers work with their attorneys to review the relevant statutes, rules and regulations to determine their responsibilities.

  • Companies must review the producer definition under each state’s packaging EPR law and determine whether they are a covered producer in California, Colorado, Oregon, and Minnesota.

  • There is no cost to register.  

  • CAA’s registration form does not include brand information, or any other kind of data not explicitly referenced in the form. Brand information and packaging material types and amounts supplied into each EPR state will be collected by CAA at a later date. CAA will communicate about next steps with the primary contact on the producer registration form.

  • There is only one registration form for all states. CAA’s registration form allows producers to select the states where the company expects to be considered a covered producer within a single form.

Helpful Tips and Information

As a registered producer, you are now eligible to participate in CAA’s Registered Producer Resource Center. CAA will also communicate about additional next steps with the primary contact on the producer registration form, including details on fees and data collection when they become available.

Next Steps

Registration FAQ

  • To comply with producer registration requirements under California, Colorado, Oregon, and Minnesota EPR laws for paper and packaging products, covered producers must register with CAA unless the producer qualifies for an exemption or the producer intends to submit an individual compliance plan, under applicable law.

    Regulations in Colorado required producers to register by October 1, 2024. Producers who did not register by that date may be subject to enforcement.CAA submitted  a list of registered producers to the Colorado Department of Public Health & Environment (CDPHE) following the October deadline.

    CAA was required to provide the Oregon Department of Environmental Quality (DEQ) with a list of registered producers as part of CAA’s revised program plan, submitted on September 27, 2024.

    Producers in these states who missed the deadline need to still register with CAA.

    Only registered producers will gain access to CAA’s 300 and 400 series producer events, data reporting preparation sessions, and producer guidance that will include detailed information on reporting and fees.

  • There is no cost to register with CAA.

  • The CAA Account Registration Form requires the following information:

    • Confirmation the company is an obligated producer based on its understanding of the legal definitions.

    • Producer’s legal business name.

    • EIN number associated with your company.

    • Company name and EIN number associated with your parent company.

    • States in which the company is likely to be considered an obligated producer.

    • Contact information, specifically:

      • Primary Contact: This person will be the first point of contact for communications with CAA. This will be the individual who will be 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 and has the ability to submit material supply data to CAA.

      • Authorized Representative: This person is authorized on behalf of the producer to bind the company, sign legal contracts and can submit material supply data to CAA.

    There is no cost to register.

  • Each company must review the producer definition under each state’s packaging EPR law and determine whether it is a covered producer in California, Colorado, Oregon, and Minnesota. CAA is not able to provide legal advice or make this determination for you.

    However, CAA has developed guidance to help businesses answer the two primary questions they need to ask that will help determine if they are obligated under the EPR laws:     

    1. Is the material associated with my products covered by the EPR laws?    

    1. Is my business the responsible producer for those materials? 

    Please review CAA’s guidance materials for further information.

    Please note that CAA guidance is not meant to constitute legal advice, and CAA assumes no responsibility for the decisions made by producers in determining their obligations. CAA suggests that producers work with their attorneys to review the relevant statutes, rules and regulations to determine their responsibilities.

    Relevant Statutes:

  • Producer exemptions differ in each state’s laws. All four states have a small producer exemption and exemptions for certain materials. Please consult with your legal counsel if you are unsure whether your company will be exempt or not. CAA is unable to provide legal advice.

  • Producers can switch their primary contact information as needed. Please email Producer.Support@circularaction.org with your name and company, and name, title, email address, and phone number of the new contact.

  • While CAA is participating in the regulatory process in Maine, the Maine Department of Environmental Protection has yet to release the Request for Proposals for prospective PROs and select a PRO. 

CAA created a Producer Resource Center to update producers on the latest developments and related obligations. CAA will communicate about next steps with the primary contact on the producer registration form. 

Producer Resources