Oregon EPR

What is Oregon EPR packaging

Oregon introduced Extended Producer Responsibility for packaging through the Plastic Pollution and Recycling Modernization Act (SB 582).

The law requires producers of packaging, paper products, and food service ware to finance improvements to the state’s recycling system.

The program is overseen by the Oregon Department of Environmental Quality (DEQ) and implemented through a Producer Responsibility Organization (PRO).

The law aims to:

• Improve recycling infrastructure
• Increase recycling rates
• Reduce contamination in recycling systems
• Shift recycling costs from municipalities to producers.

Does this apply to e-commerce & online sales

Yes. Oregon EPR compliance for online sellers applies to products shipped into Oregon, including packaging used for e-commerce and online sales.

If packaging is used to deliver products to Oregon consumers, it may fall under the EPR program.

Who is the "producer" under Oregon EPR

Under Oregon EPR, the producer is typically:

1. The brand owner whose name appears on the product
2. If the brand owner is located outside the United States, the importer
3. If neither applies, the distributor or retailer

Only one company is responsible for the packaging.

Who must register for EPR packaging in Oregon

Companies placing covered EPR registration for packaging or paper products on the Oregon market must:

• Join an approved Producer Responsibility Organization (PRO)
• Report packaging data
• Pay EPR eco-fees.

Oregon EPR packaging registration threshold

For EPR packaging thresholds Certain small producers may be exempt if they:

• Have less than $5 million in annual revenue, or
• Sell less than 1 ton of covered material per year into Oregon.

Companies exceeding these thresholds must comply with the EPR program.

Packaging covered (and excluded)

Covered packaging

The Oregon EPR program covers:

• Product packaging
• E-commerce shipping packaging
• Paper products
• Food service ware.

Covered materials include:

• Plastic packaging
• Paper and cardboard
• Glass packaging
• Metal packaging.

Excluded packaging

Certain packaging types may be excluded, including:

• Medical packaging
• Hazardous materials packaging
• Packaging regulated by federal law.

Producer Responsibility Organization (PRO)

Oregon approved Circular Action Alliance (CAA) as the Producer Responsibility Organization responsible for managing the program.

The PRO will:

• Collect packaging data from producers
• Calculate eco-fees
• Fund recycling system improvements
• Report compliance to Oregon regulators.

EPR registration in Oregon

Producers must register with the PRO (Circular Action Alliance) rather than directly with the state.

Registration includes:

• Providing company information
• Reporting packaging data
• Paying annual eco-fees.

Authorized representative

Foreign producers selling into Oregon may need a U.S.-based entity or representative responsible for compliance.

What data must be reported

Producers must EPR report packaging data including:

• Material type (plastic, paper, glass, metal)
• Packaging weight
• Packaging format
• Quantity placed on the Oregon market.

This information is used to calculate eco-fees.

First reporting period

Oregon EPR reporting officially launched its producer registration in 2024, with producers required to submit packaging data for the program rollout.

The recycling modernization program will gradually expand over the coming years.

EPR reporting deadlines

Key milestones include:

• 2024 – producer registration begins
• July 2025 – new recycling system improvements start
• Ongoing annual reporting and fee payments.

Labels & marketing claims

Oregon EPR does not introduce a mandatory recycling logo for packaging. Producers are expected to follow standard U.S. labeling practices, including the voluntary How2Recycle label system and FTC Green Guides requirements for environmental claims.

An example of what a label looks like on packaging sold in Oregon

This packaging shows How2Recycle labels commonly found on products sold in Oregon. Each label identifies disposal instructions per component: the Paper Box is recyclable curbside ("Recycle if Clean & Dry"), while the Plastic Bag requires store drop-off. The Paper Card is recyclable, while the Plastic Tray is not — consumers are instructed to separate components before disposal. The How2Recycle label is a voluntary standardized system widely adopted by U.S. brands; it is not mandated by Oregon law.

📎 Download the How2Recycle symbols:

•  PNG – best for digital use.
• SVG  - ideal for printing and scaling.

EPR eco fees & eco-modulation

Producers must pay eco-fees based on:

• Packaging material
• Packaging weight
• Recyclability
• Environmental impact.

Eco-modulation encourages producers to adopt more sustainable packaging designs.You can estimate potential packaging compliance costs with Lappa’s EPR fee calculator based on packaging material and volume. For registration, reporting and ongoing compliance service costs, see Lappa’s EPR pricing page.

Risks, penalties & common mistakes

Non-compliance may lead to:

• Financial penalties
• Enforcement actions
• Restrictions on selling products in Oregon.

Common mistakes include:

• Not identifying the responsible producer
• Missing registration deadlines
• Incorrect packaging data reporting.

What e-commerce sellers should do now

Companies shipping products to Oregon should:

• Identify whether they qualify as a producer
• Track packaging materials used in shipments
• Register with the PRO if required
• Prepare packaging data for reporting.

FAQ

• Is Oregon EPR already active

Yes, the program is currently being implemented.

• Does this apply to online sellers

Yes, if packaging is used to ship products to Oregon consumers.

• Is there a mandatory recycling logo

No. Oregon EPR focuses on reporting and financing recycling systems rather than mandatory packaging labels.