Producer Registration

CAA is the Producer Responsibility Organization (PRO) approved to implement EPR laws for paper and packaging in California and Colorado, and the only paper and packaging PRO to submit a program plan in Oregon.

To comply with producer registration requirements in California's, Colorado's, and Oregon's EPR laws for paper and packaging products, covered producers must register with CAA by July 1, 2024, unless the producer qualifies for an exemption or the producer intends to submit an individual compliance plan, under applicable law.

How to Register

Any company that expects to be considered a covered producer under California, Colorado, and/or Oregon’s paper and packaging EPR laws, and which is not otherwise exempt from registration under those laws, must complete the Covered Producer Registration form as the first step in the producer registration process with CAA by July 1, 2024.

The Covered Producer 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.

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

  • Primary contact’s email address and phone number. This will enable CAA to notify your company when it is time to accept the applicable requirements of CAA’s producer responsibility program plans.

Companies will have an opportunity to update information if needed.

Producers who complete CAA’s registration form before July 1, 2024, will be considered registered with CAA. The primary contacted listed will receive a confirmation email upon completing the registration form. Please save this email for your records.

Helpful Tips and Information

  • Companies must review the producer definition under each state’s packaging EPR law and determine whether it is a covered producer in California, Colorado, and/or Oregon (Learn More). 

  • There is no cost to register with CAA by the July 1, 2024, deadline.  

  • CAA needs at least one point of contact per producer company. This will be the individual who will be notified of upcoming requirements and any requests for information or follow-up conversations with CAA. The primary contact may include others in future requests or discussions, and a company may choose to appoint a new primary contact at any time. If there are additional employees who would like to receive CAA updates, they are encouraged to sign up for CAA’s monthly newsletter. 

  • 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.

  • CAA requests only one registration per company. If you are the parent company of one or more subsidiaries that will have obligations under the law, parent company registration will be sufficient at this stage in the process. Individual subsidiaries do not need to submit contact information. 

  • 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.

Penalties for Not Registering

Unless a producer intends to submit its own plan in Colorado, it is required to register with CAA by July 1, 2024. Failure to register may result in the Colorado Department of Public Health and Environment (CDPHE) imposing fines. In all states, registration will help ensure producers receive reporting guidance and will provide CAA with needed data to set accurate fees. 

CAA will communicate about next steps with the primary contact on the producer registration form, including details on fees and data collection when they become available.

Next Steps

Producer Definitions

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, and/or Oregon. 

  • Please consult with your legal counsel if you are unsure and make a selection based on the information currently available. CAA is unable to provide legal advice.

  • Companies will have an opportunity to amend their registrations if needed. The definition of “Producer” varies in each state's law, and you should work with your legal counsel to verify where your company may have legal obligations.

  • If there is no brand owner or domestic producer responsible for a brand, then the producer may be the packaging manufacturer or the company that first imports the product and the associated packaging into the United States. In Oregon, the obligated entity for foodservice ware is the supplier.

If you require more information, please consult with your legal counsel and check CAA’s Producer Compliance Center.

Exemptions: Producer exemptions differ in each state’s laws. All three 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. 

Relevant Statutes:

If Questions Remain: Please consult with your legal counsel if you are unsure if your company is covered, and make a selection based on the information currently available. CAA is unable to provide legal advice. Companies will have an opportunity to amend their registrations if needed.  

CAA is developing guidance materials to provide clarity to producers on their obligations under each state’s law, including the definition of obligated producer, materials included in the state’s program, and material data reporting requirements. This guidance will be finalized and shared with producers in 2024, as regulations are finalized. In the meantime, producers may also review CAA’s Producer Compliance Center for more information.  

Registration FAQ

  • CAA’s registration form collects similar information to CAA’s previous Obligated Producer Survey, however producers must complete the new form to register with CAA. CAA will contact all producers that filled out the Obligated Producer Survey to ensure contact information is up to date.

  • Your company must review the producer definition under each state’s packaging EPR law and determine whether your company is a covered producer in California, Colorado, and/or Oregon.

    Please consult with your legal counsel if you are unsure and make a selection based on the information currently available. CAA is unable to provide legal advice. Companies will have an opportunity to amend their registrations if needed.

    CAA is developing guidance materials to provide clarity to producers on their obligations under each state’s law, including the definition of obligated producer, materials included in the state’s program, and material data reporting requirements. This guidance will be finalized and shared with producers in 2024, as regulations are finalized. In the meantime, producers may also review CAA’s Producer Compliance Center for more information.

  • Producer exemptions differ in each state’s laws. All three 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.

  • If you are the parent company of one or more subsidiaries that will have obligations under the law, parent company registration will be sufficient at this stage in the process. Individual subsidiaries do not need to submit contact information.

  • There is no cost to register with CAA by the July 1, 2024, deadline.

  • 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. To date, CAA has been approved as the single PRO in California and Colorado and expects to be the approved PRO in Oregon once CAA’s program plan is approved.

  • The primary contact should be a person who is authorized to act on behalf of the producer. CAA will send all information regarding compliance to the primary contact listed. Companies should use their discretion in determining the correct contact.

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

Producer Resources

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.