SB 582 · enacted 2021

Oregon packaging EPR: what you owe and when

Plastic Pollution and Recycling Modernization Act. Current phase: Operating: producer fees charged since July 2025.

Facts last verified 14 September 2026.

Estimate your Oregon fee

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Am I covered

For packaging sold in Oregon the producer is the manufacturer if the item carries its own brand or no brand, and otherwise the brand licensee. If neither is in the United States, it is the importer bringing the item in for sale in Oregon. For remote sales, whoever packs and ships the item is the producer of the shipping packaging. A manufacturer includes a company that directs manufacturing, for example by setting packaging specifications.

Source: ORS chapter 459A and OAR 340-090-0860 , ORS 459A.866; OAR 340-090-0860(1). Verified 14 September 2026.

The exemption

A small producer does not have to join a producer responsibility organization. Small producers are nonprofits, public bodies, producers with gross revenue under $5 million in their most recent fiscal year, producers that sold less than one metric ton of covered products into Oregon in the most recent calendar year (five metric tons for beverage manufacturers), restaurants and food carts that are not producers of food serviceware, and single retail stores with no online sales that are not part of a franchise or chain.

Source: ORS chapter 459A , ORS 459A.863(32); ORS 459A.872(1). Verified 14 September 2026.

What the threshold is measured against

The Oregon DEQ reads the $5 million test as gross global revenue, not Oregon sales. The tonnage tests count the weight of covered products sold into Oregon. Associated companies, such as those under more than 50 percent common ownership, add their revenues and Oregon volumes together before the thresholds are applied.

Source: Oregon DEQ, Frequently Asked Questions: Recycling Modernization Act Exemptions (updated April 9, 2026) , ORS 459A.863(32); OAR 340-090-0860(6). Verified 14 September 2026.

What you owe

Registration

Every producer that is not a small producer must register with and be a member of a producer responsibility organization, unless another company has registered as the responsible producer for all of its covered products. The Oregon DEQ directs producers to register through Circular Action Alliance.

Source: Oregon DEQ, Producers of Covered Products , ORS 459A.869; ORS 459A.872(1). Verified 14 September 2026.

Who runs the program

Circular Action Alliance, Oregon's only approved producer responsibility organization. The Oregon DEQ approved its 2025 to 2027 program plan on February 21, 2025, and has approved amendments since.

Source: Oregon DEQ decision letter to Circular Action Alliance (February 21, 2025) , ORS 459A.878(1). Verified 14 September 2026.

Reporting

Every year producers report to their producer responsibility organization, not to the Oregon DEQ, the weight of covered products they sold into Oregon and how they calculated it. From 2026, fees are set from supply data two years before the program year, and the organization reports supply totals to the DEQ by July 1.

Source: Oregon Administrative Rules, OAR 340-090-0700 , OAR 340-090-0700; ORS 459A.869(5). Verified 14 September 2026.

Fee schedule

Actual rates for program year 2026, per category, as published. Not a range and not an average.

Source: Circular Action Alliance, "2026 Oregon Producer Fee Schedule", originally published 2025-10-29, retrieved 2026-07-12, https://circularactionalliance.org/s/OR-2026-Fee-Schedule-Public.pdf (Final rate for 'Newspapers') . Program year 2026. Verified 12 July 2026.

Eco-modulation

In force, but only as bonuses so far. The approved plan offers fee reductions for packaging assessed with a life cycle evaluation, including a bonus of 10 percent of base fees on the assessed packaging, capped at $20,000, and tiered bonuses for measured impact reductions and for switching to reusable or refillable packaging. The plan has no fee increases yet, although the statute requires both.

Source: Oregon DEQ decision letter on the Circular Action Alliance eco-modulation plan amendment (September 12, 2025) , ORS 459A.884(4); OAR 340-090-0910(3). Verified 14 September 2026.

Timing: the year you sell is not the year you pay

This is the part that catches people out. Packaging you sell in one year is reported the next and invoiced after that, so the cost lands in a later budget than the sales that created it.

• 2024 You sell packaging into Oregon. This is the data year.
• 2025 You report that year's supply.
• 2026 You are invoiced for it. Budget the cost here, not against the year you sold.

Source: OAR 340-090-0700(1)(b): "From 2026 onward, a producer responsibility organization will set producer fees using supply data from two years prior to that program year. For example, 2028 fees will be set on the basis of 2026 supply data." Retrieved 2026-09-15 from https://secure.sos.state.or.us/oard/view.action?ruleNumber=340-090-0700 . So the 2026 invoice prices 2024 supply, and 2027 onward follows the same two-year lag; this agrees with CAA (Program Year = Data Year + 2) and Oregon DEQ (the 2025 supply report sets 2027 fees), both retrieved 2026-08-18. The 2025 row is the startup exception: the rule set the 2025 program year on interim market share (subsection (1)(c)) and CAA billed 2024 supply on it, so 2024 supply was billed on both the 2025 and 2026 invoices. That row is cited to CAA's own statement: Oregon's first producer supply reporting cycle closed on 31 March 2025 and set "the final fee schedule, which will be used for invoicing in late May 2025", with fees payable from 1 July 2025 (CAA news release, "CAA Marks Significant Progress ... with the Conclusion of Oregon's First Producer Supply Reporting Cycle on March 31, 2025", https://circularactionalliance.org/news-feed/caa-deadline-producer-registration-approaching-p6f9m-6z3bk , retrieved 2026-09-15; the cycle reported calendar-2024 supply per Oregon DEQ, retrieved 2026-08-18). Every invoice year from 2026 is the rule..

If you do not comply

A civil penalty of up to $25,000 per day for each day of violation. Failing to register with or join a producer responsibility organization is a Class I violation, and the Oregon DEQ may ask the Department of Justice to stop a noncompliant producer selling covered products into Oregon.

Source: ORS 459.995, Civil penalties , ORS 459.995(1)(a); ORS 459A.962; OAR 340-012-0098(1)(a). Verified 14 September 2026.

Recent changes

August 28, 2026: the Oregon DEQ announced that the federal district court ruled the Act does not violate the dormant Commerce Clause or the Due Process Clause, after a July 2026 trial in the National Association of Wholesaler-Distributors case.

Source: Oregon DEQ news release, Oregon Recycling Modernization Act Upheld as Constitutional . Verified 14 September 2026.

May 4, 2026: the Oregon DEQ approved a plan amendment setting how responsible end markets are verified.

Source: Oregon DEQ decision letter to Circular Action Alliance (May 4, 2026) , ORS 459A.878(1). Verified 14 September 2026.

September 1, 2026: Circular Action Alliance submitted a third plan amendment revising the material categories producers report against. The DEQ takes public comments until October 19, 2026.

Source: Circular Action Alliance letter to the Oregon DEQ (September 1, 2026) , ORS 459A.881. Verified 14 September 2026.

Other state guides

• California packaging EPR
• Colorado packaging EPR
• Washington packaging EPR
• Minnesota packaging EPR
• Maryland packaging EPR
• Maine packaging EPR

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Run your own numbers

Enter what you supply into Oregon, in pounds, against this state's own reporting categories. You get a fee with the public document behind every rate it used.

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