Upcoming Deadlines for Producers Required to Join a Producer Responsibility Organization in Oregon

Oregon’s Department of Environmental Quality (DEQ) has issued a notice as it relates to upcoming producer obligations that include joining the Producer Responsibility Organization (PRO) by March 31, 2025 under the state’s consumer packaging waste EPR law, the Recycling Modernization Act. Primary and tertiary packaging for wine being sold and distributed into Oregon may have producer obligations and therefore we advise members to review the notice below and Wine Institute’s OR EPR Laws section of our website.

Upcoming Deadlines for Producers Required to Join a Producer Responsibility Organization (DEQ, Feb. 5, 2025)

DEQ would like to communicate some important approaching deadlines to producers obligated to join a Producer Responsibility Organization, report supply data and pay fees under the Recycling Modernization Act.

1.) Pursuant to OAR 340-090-0870, producers must register with and report their 2024 supply data for Oregon to PRO Circular Action Alliance by March 31, 2025. CAA’s reporting portal is opening this week and CAA is making guidance documentation available to all registered producers to enable timely and correct reporting. CAA is also hosting a suite of webinars to support producers with meeting this first reporting deadline. Accurate reporting and robust producer engagement for this first deadline is key to enabling CAA to accurately set fees for the first program year. Note: producers must report their gross supply volumes for 2024 to Circular Action Alliance for the March 31, 2025 deadline, including volumes that may qualify for the exemption for materials recycled outside the commingled system (see item #3 below). Before invoicing for 2025 fees, CAA will subtract the exempted volumes from each producer’s report.

2.) The obligation on producers to pay fees for the covered products that they sell or distribute in or into the state kicks in on July 1, 2025. Producers may receive fee invoices prior to that date.

3.) Pursuant to ORS 459A.869(13), producers may claim an exemption from the requirement to pay fees for the proportion of their products that is recycled outside of the commingled system. DEQ and CAA presented on the process for claiming this exemption during a webinar on Tuesday, February 4, at 9:00-10:30am PT. Watch the recording of the webinar here. The window for submitting exemption claims opened immediately after the webinar and will extend until Friday, March 7, at 5:00PT, with the blank claim form and other information available here. Exemption decisions will be finalized by May 1, 2025.