Update Circular Action Alliance has asked that obligated Producers register and enter into a Participant Producer Agreement by December 31, 2024. Obligated Producers will report on March 31, 2025, using data from 2024 (full year). Final fees will be assessed in July 2025.
Circular Action Alliance has asked that obligated Producers register and enter into a Participant Producer Agreement by December 31, 2024.
Obligated Producers will report on March 31, 2025, using data from 2024 (full year). Final fees will be assessed in July 2025.
Oregon’s packaging law, enacted in August 2021 and scheduled for implementation by July 2025, encompasses packaging, paper products, and food serviceware. Producers defined under this legislation are identified based on the manner of packaging and distribution.
For items sold with packaging at physical retail locations under the manufacturer’s brand, the brand itself is designated as the producer. If packaging lacks brand identification, the producer is the entity that manufactures the packaged item. Imported items are the responsibility of the distributor or importer if not produced within the US but sold in the state.
The Circular Action Alliance is the registered PRO overseeing compliance, with Producers required to report data starting from 2024 and register by July 2025. This legislation aims to regulate environmental impacts by ensuring responsible handling and management of packaging materials within Oregon.
If your company sells into Oregon, this may affect your reporting, internal data collection, packaging decisions, and long-term compliance planning.
Depending on your role in the supply chain, your organization may be considered the obligated producer. That responsibility can fall to the brand owner, trademark owner, licensee, importer, or distributor. For many companies, the real challenge is not just understanding the law — it is figuring out who is responsible internally, what information is needed, and how to prepare without overloading already stretched teams.
EPR is evolving across the U.S. What starts in one state can quickly become part of a much larger operational and financial burden
The best time to prepare is before compliance pressure builds. A practical first step is to confirm whether your company is obligated and identify what data, teams, and systems will be needed to respond.
From there, organizations should begin reviewing:
Getting ahead now can reduce compliance risk, prevent last-minute reporting pressure, and help your team build a more manageable path forward
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