Circular Action Alliance to accept reports through April 30, 2025
Circular Action Alliance (CAA) recently announced a grace period through April 30, 2025 for producers to report data by weight and material category for all packaging, paper, and food-service ware items sold to consumers or businesses in the state.
The first reporting deadline for producers to report data to CAA for all covered material sold in Oregon was March 31, 2025, per state regulations.
Data reported by April 30, 2025 will affect CAA’s fee rate calculations for Oregon, and CAA has indicated that the more total material in each category is reported, the lower the fee for that category will be.
This week, CAA will provide to Oregon’s Department of Environmental Quality (DEQ) a list of companies that have not yet reported. Oregon’s extended producer responsibility (EPR) statute provides a program start date of July 1, 2025, and DEQ may assess civil penalties against noncompliant companies.
This and other new EPR obligations will take effect in 2025, requiring producers to report data, pay fees based on the weight and type of packaging they report, and begin transitioning toward more recyclable or compostable materials and reducing the use of plastics. These rollouts may influence how other states and regulators structure EPR programs.
Companies are encouraged to understand their compliance obligations if they manufacture or sell packaged products, provide or sell disposable food-service ware, make or distribute paper products, or ship products to businesses or consumers.
As companies navigate these requirements, key questions to focus on include:
- Who will manage the reporting process in 2025?
- What are the upcoming producer reporting deadlines in Oregon, California, and Colorado?
- What producer fees are expected?
- What exemptions may apply to your business?
- What are the requirements in California to reduce plastic materials?
- What are the reporting guidelines and timelines for Maine and Minnesota?
- What are the next steps for compliance teams?
- What other EPR developments are on the horizon?
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