March 10, 2025
What’s happening?: On March 31, producers, manufacturers and importers of packaging, printing and writing paper and food servicewear must register and report to the Circular Action Alliance. The requirement is part of the Recycling Modernization Act (RMA).
What’s the RMA?: The RMA is a recycling law created by the Oregon Legislature in 2021 through the passage of SB 582. In simplest terms, the law pushes the responsibility for recycling upstream to companies that produce packaging, paper products and food servicewear. Producers must join (and pay fees to) a nonprofit producer responsibility organization (PRO). The PRO, in turn, will fund various recycling improvements and ensure that recyclable material finds its way to appropriate end markets.
Oregon’s PRO: The Circular Action Alliance is Oregon’s only approved PRO. In February 2025, the CAA announced that DEQ had approved its 250-page program plan, which can be found here.
Lengthy implementation: It has taken the Oregon Department of Environmental Quality years to develop rules for the RMA, in part because the scheme is largely untested. Oregon became the third state to adopt a so-called extended producer responsibility law, following California and Maine. But Oregon’s program is scheduled to be the first in operation.
Implementation date: Implementation is scheduled for July 1, 2025, by which time producers must have joined a PRO.
How to register: First, though, producers must register with a PRO by March 31. The CAA provides guidance for Oregon producers here. Following registration, the CAA will share next steps, including details on fees and data collection when they become available.
Learn more: Both the CAA and DEQ have made additional information about the program available, including:
- The CAA’s online blog and newsroom contain useful information, including a March 5 post providing basic information about the program and the March 31 reporting deadline.
- The DEQ’s Recycling Modernization Act web page has a great deal of information, including a FAQ, fact sheet, implementation timeline and more.


