On April 9, 2026, Oregon’s Department of Environmental Quality published its first list of producers flagged as noncompliant with the state’s Recycling Modernization Act, the extended producer responsibility (EPR) law covering packaging and paper products.
The list, posted to the Circular Action Alliance (CAA) website the next day, names roughly 250 companies. For any brand managing packaging compliance across states, it’s a clear signal: Oregon’s program is active, and producers are expected to know where they stand.
How the process works
CAA first contacts a producer about a suspected gap in registration, reporting, or fee payment and gives 90 days to respond. If the gap isn’t resolved, CAA refers the case to DEQ, which issues a formal notice and a 30-day window to come into compliance. From there, the producer’s name goes public on the Oregon Producer Membership Registry.
The upside of understanding this process early is real. Penalties for noncompliance can reach $25,000 per day, and in serious cases the Oregon Department of Justice can restrict product sales in the state.
Producers who get ahead of these requirements avoid that risk entirely, and many are finding that leveraging EPR as an opportunity to advance the sustainability of their packaging comes with monetary benefit: For example, Oregon offers eco-modulation discounts for third-party-reviewed life cycle assessments and California and Colorado offer discounts for the inclusion of post-consumer recycled material.
Business value comes from reduced EPR fees and an opportunity to gain consumer trust through concrete action.
Turn compliance into an advantage
A delinquency notice, or simply an unclear sense of your obligation, is a good moment to build a stronger foundation. 3R Sustainability’s Product and Packaging team helps producers move from uncertainty to clarity and turn compliance into an advantage:
- Obligation assessment: Get clarity on whether you’re an obligated producer and what packaging counts, so decisions rest on facts instead of guesswork.
- Registration and reporting support: Get registered with CAA and current on packaging data submissions, with a process built to hold up year after year.
- Fee analysis and estimates: Know what you owe and where eco-modulation discounts apply.
- Regulatory monitoring: Stay ahead of deadlines and rule changes across Oregon and other EPR states, so compliance stops being a scramble.
- EPR program management plan: Build a documented, audit-ready process that turns this year’s fire drill into next year’s routine.
Reach out to 3R for support
3R offers this support through three tiers: Enablement, Co-Managed, and Full-Service, scaled to how much your team wants to handle in-house versus hand off entirely.
A delinquency notice isn’t the end of the story. It’s the starting point for a stronger compliance program. Reach out to 3R Sustainability to map out your next step.