Oregon passes Plastic Pollution and Recycling Modernization Act

With federal climate legislation backsliding, states are taking the lead on environmental accountability. Oregon’s Plastic Pollution and Recycling Modernization Act (RMA) was passed in 2021 and took effect on July 1, 2022. It is part of a growing wave of Extended Producer Responsibility (EPR) laws in Maine, Colorado, California, and Minnesota aiming to increase transparency and shared responsibility across supply chains.

For businesses still questioning whether to keep investing in climate action and corporate sustainability, Oregon’s approach makes the answer clear: leadership now prevents non-compliance later.

The summary below outlines who the law applies to, key requirements, and the implementation timeline.

Recycling Modernization Act (RMA) summary

Oregon’s RMA requires companies that contribute to the recycling waste stream to fund improvements and expand accessibility of recycling services statewide.

The law increases accountability for “Producers”, including companies that sell packaged products in Oregon and those that manufacture or supply the packaging itself. Responsibility is scaled based on each producer’s contribution to the recycling stream, including the materials used, the design and recyclability of packaging, and the volume of products sold into the state.

To comply, producers must join a state-approved Producer Responsibility Organization (PRO) that manages reporting, fee collection, and system improvements on behalf of its members. Oregon has designated Circular Action Alliance (CAA) as the PRO responsible for implementing the RMA.

Companies that must comply with the RMA

A “Producer” is any company that first sells, distributes, or offers covered products for sale in Oregon. Depending on how a business operates, responsibility may apply to:

• Brand owners whose name or logo appears on a product or its packaging sold in Oregon
• Importers or distributors that bring products or packaging into Oregon when the brand owner is based outside the state or country
• Manufacturers or suppliers that take on producer responsibility by contract, including for packaging or materials used in covered products
• Businesses that package, label, or ship products for sale in Oregon, when no other party meets the definition of a producer

Covered products:

• Food service ware (e.g. cups, plates, bowls, cutlery, takeout containers)
• Paper products (e.g. newspapers, catalogs, magazines, office or copy paper)
• All other packaging materials used to contain, protect, or ship products (e.g. plastic, glass, metal, paperboard, flexible film, composite materials)

Exemptions include but are not limited to:

• Operators of a single retail establishment with no online sales and not part of a franchise or chain
• Businesses with less than $5 million in annual global revenue or that sold under 1 metric ton of covered products in or into Oregon during the previous calendar year

Recycling Modernization Act requirements

As part of Oregon’s Extended Producer Responsibility (EPR) program, the state’s top 25 producers are required to evaluate and publicly disclose the life cycle impacts of their packaging and products. All other producers must register with a PRO and may choose to submit reports to qualify for financial bonuses tied to verified impact reductions.

Life cycle analysis (LCA) requirements

• Scope: Producers must complete cradle-to-grave LCAs following ISO 14044:2006 and the Product Environmental Footprint (PEF) method
• Impact categories: Each LCA must assess 16 environmental impact categories defined in the PEF method, including climate change, eutrophication, acidification, resource depletion, and more
• Additional inventories: plastic leakage (including microplastics), methane leakage calculation, and hazardous waste impact assessment
• Reporting format: Producers must submit up to two versions per SKU, one marked “Exempt from Disclosure; Confidential” and the other “Public Report”
• Verification: Each LCA must be audited by a qualified third party to confirm completeness and compliance with Oregon Department of Environmental Quality (DEQ) requirements. Audit statements must accompany submission

Submission and timing

Reporting begins in 2026 and every two years thereafter, at minimum for mandatory reporting.

Coverage threshold: the top largest producers (by sales volume) must report on at least 1% of covered products every two years; they are ineligible for reporting bonuses.

Fee adjustments

Eco-modulated fees are higher for products that generate more waste or contain harmful materials, and lower for those with proven environmental improvements.

The Circulation Action Alliance also offers a scheme to reduce annual fees through LCA reporting and demonstrable impact reductions.

• Bonus A: Granted for conducting and disclosing LCAs for up to 10 SKUs
• Bonus B: Granted for LCAs demonstrating substantial environmental improvements to packaging
• Bonus C: Granted for LCAs showing impact reductions from switching to reusable or refillable formats

Third-party oversight and transparency

• Audit Requirement: Third-party auditors must verify that LCAs meet DEQ standards prior to submission
• Public Access: Public versions of reports are required for transparency and accountability

Recycling Modernization Act timeline

Legal challenges impacting Recycling Modernization Act

On April 9, 2025, the U.S. federal executive order titled, “Protecting American Energy from State Overreach”, was signed, directing the U.S. Attorney General to identify and challenge state-level climate laws and policies that may be unconstitutional or preempted by federal law. As a result, the implementation or enforceability of state regulations such as Oregon’s RCA may be subject to legal review or change.

For ongoing updates on climate disclosure laws, see ClimatePartner’s U.S. Climate Regulation Tracker.

How ClimatePartner supports compliance with the RMA

Navigating new Producer responsibility laws can be complex, but you don’t have to do it alone. ClimatePartner supports companies through every stage of Oregon’s Recycling Modernization Act compliance, including:

• Conducting life cycle impact assessments across all 16 environmental indicators
• Performing methane leakage calculations and plastic leakage inventories
• Preparing full ISO-aligned reporting consistent with Oregon requirements
• Providing third-party audit and verification support

Reach out today to see if you are compliance-ready.