Washington State's Organics Management Law: The Commercial Threshold Just Hit 96 Gallons Per Week

Washington State has two separate solid waste programs that affect commercial operators: the Organics Management Law (HB 1799, enacted 2022) and the newer Recycling Reform Act (SB 5284, signed 2025). The two programs target different problems with different timelines, and both are now active.

Program 1: Organics Management Law

Citation: RCW 70A.205.540, HB 1799 (enacted 2022).

The Organics Management Law phases in commercial organics diversion across three thresholds:

- January 1, 2024: businesses generating 8+ cubic yards per week of organic waste - January 1, 2025: businesses generating 4+ cubic yards per week - January 1, 2026: businesses generating 96 gallons per week (about 0.5 cubic yards)

Current Threshold: 96 Gallons per Week

As of January 1, 2026, the current active threshold is 96 gallons per week — approximately a half cubic yard. This sweeps in the vast majority of commercial food service operations of any meaningful size: most restaurants, all grocery stores, hospital and institutional food service, hotels with food facilities, and food manufacturers.

Compliance means arranging for organics collection to composting, anaerobic digestion, or similar diversion. Exceptions exist for areas of Washington with no available organics service infrastructure.

Program 2: Recycling Reform Act (SB 5284)

Signed into law on May 17, 2025, and codified as Chapter 70A.208 RCW. This is Washington's packaging EPR program.

PRO: Circular Action Alliance (CAA), the same PRO that administers EPR programs in several other states.

Current Phase: Phase 1 Buildout

The program is currently in Phase 1 buildout:

- Service providers are registering with the Washington Department of Ecology - An advisory council is forming - Needs assessments are underway

No producer fees are required yet during this buildout phase.

Upcoming Milestones

After March 2029: producers not participating in the PRO cannot sell covered products in Washington.

2030: producer fees begin phase-in. The PRO must reimburse 90% or more of recycling costs.

Statewide harmonized recycling collection lists are required, meaning Washington jurisdictions will collect the same defined materials so producers and consumers have consistent recyclability expectations across the state.

The Combined Compliance Picture

Commercial operators with Washington locations are now subject to:

- Organics Management Law for food and organic waste streams (96 gallons/week threshold) - Recycling Reform Act for packaging compliance (during buildout now; full enforcement later) - Local jurisdiction recycling requirements

How ICTV Helps

ICTV helps multi-site operations with Washington footprints document organics diversion at every covered site, structure compliant programs at the 96-gallon threshold, and prepare for the packaging EPR enforcement phase that begins in 2029-2030.

For operations selling packaging into Washington in addition to having physical sites, the dual exposure to both programs means consolidated documentation across organics diversion and material stream reporting becomes operationally important.