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CAA Announces July 1 Deadline for Producers Subject to EPR laws in Three States

Stacks of binders of regulations

The Circular Action Alliance (CAA) is the Producer Responsibility Organization designated by California, Colorado, and Oregon to administer their Extended Producer Responsibility (EPR) Programs for packaging. CAA has stated on its website that:

 “Any company that expects to be considered a covered producer under California, Colorado, and/or Oregon’s paper and packaging EPR laws, and which is not otherwise exempt from registration under those laws, must complete the Covered Producer Registration form as the first step in the producer registration process with CAA by July 1, 2024.” (See EPR for Paper and Packaging Resources — Circular Action Alliance.)

This deadline has been established even though the regulations for the EPR laws in these states have not all been finalized. CAA has stated that companies will have an opportunity to update information if needed. For example, the CAA registration form does not include brand information. The organization explained that “[b]rand information and packaging material types and amounts supplied into each EPR state will be collected by CAA at a later date.”

In addition, CAA is developing guidance materials for producers on their obligations under each’s law, including the definition of obligated producer. However, the guidance will only be finalized as regulations are finalized. For now, CAA advises companies to review the producer definitions under each state’s packaging EPR law to determine if it is a covered producer.

Colorado’s EPR program for packaging was established by HB 22-1355; Oregon’s EPR program was established by SB 582; and California’s EPR was established by SB 54. For background information on these laws, see the articles, Extended Producer Responsibility Programs for Food Packaging: Balancing Source Reduction with Food Safety and California Begins Formal Rulemaking on Plastic Pollution Producer Responsibility Act. Each state EPR law encompasses different products, with some – like California – including all types of single-use packaging (not just plastic), including single-use packaging for raw materials sold in California.