Oregon's Recycling Modernization Act: What Producers Selling in Oregon Must Do Now

Oregon SB 582, officially titled the Plastic Pollution and Recycling Modernization Act (RMA), was signed in 2021 and is the first packaging EPR program in the United States to enter active fee collection. Producers selling covered packaging, paper products, and food serviceware in Oregon are now in the live compliance phase of the program.

Administering Agency and PRO

The Oregon Department of Environmental Quality (DEQ) administers the RMA. The Producer Responsibility Organization (PRO) is the Circular Action Alliance (CAA), approved by DEQ on February 21, 2025 as Oregon's only approved PRO.

Who the RMA Applies To

The law covers:

- Brand owners selling packaging into Oregon - Manufacturers of packaging, paper products, and food serviceware sold in Oregon - Importers of finished goods packaged in covered materials

Small producers, defined under ORS 459A.863(32), are exempt. The threshold is based on annual gross revenue and material volume.

What's Active Now

First producer reporting deadline (2024 supply data): March 31, 2025. Producers who missed this deadline are out of compliance.

CAA began invoicing more than 3,000 producer companies in July 2025.

Second reporting deadline (2025 supply data): anticipated May 31, 2026.

The first approved program plan covers 2025-2027.

Life cycle impact disclosure for top 25 producers by market share is due December 31, 2026.

Penalties

Failing to register with CAA or pay required fees is a Class 1 violation under Oregon law, carrying penalties of up to $25,000 per day.

The Oregon Department of Justice may prohibit sale of non-compliant products in Oregon.

The NAW Injunction

In mid-2025, a federal court issued a preliminary injunction protecting member companies of the National Association of Wholesaler-Distributors (NAW) from enforcement of producer fees pending litigation. Trial is set for July 2026.

This injunction does not cover all producers. It applies specifically to NAW member companies. Non-NAW producers remain under full compliance obligations.

Producers should not assume the injunction shields them unless they are NAW members and have confirmed the protection applies to their specific operations.

What This Means for Multi-State Operators

For operations selling into multiple states with EPR programs (Oregon, California, Colorado, Maine, Minnesota, Washington), the documentation burden compounds. Each state's program has its own reporting deadlines, fee structures, and material categories.

A consolidated material stream documentation system that can be sliced by state of sale becomes the operational foundation for producer compliance across the full footprint.

How ICTV Helps

ICTV serves operations with multiple state footprints by organizing material stream documentation that supports producer compliance reporting under Oregon, California, and other state EPR programs. Diversion and material recovery data is provided in formats that can be aggregated by jurisdiction, by material category, or by site.