As state legislatures continue to pursue extended producer responsibility (EPR) programs and regulations, NAW continues to monitor and analyze these bills to understand how each may impact wholesaler-distributors conducting business in that state. For context, EPR is a policy approach that makes “producers” (which can include distributors who sell into the state) responsible for their products throughout the entire lifecycle, including at the post-consumer stage. Seven states (CA, CO, ME, MD, MN, OR, and WA) have enacted packaging EPR laws thus far.

Leading the rollout of these programs is Oregon, whose plastic and paper packaging EPR program has statutorily begun today, July 1, 2025. As such, the state’s only approved producer responsibility organization (PRO) Circular Action Alliance will begin collecting “membership fees” for 2024 sales from registered “producers”. Given the complex and unclear nature of this program, NAW sent a letter and submitted public comments to the Oregon Department of Environmental Quality (DEQ) requesting that implementation of the program be delayed at least one year. Last week, Oregon DEQ responded and denied our extension request. More information about the Oregon program can be found here. Additional resources on determining Oregon’s “producer obligations” and which producer has compliance obligations can be found here.