Do You Need to Join a Producer Responsibility Organization? Updates for Oregon, California, Colorado, Maine and Maryland

Who is Circular Action Alliance (CAA)?

They are a non-profit Producer Responsibility Organization (PRO) dedicated to implementing effective Extended Producer Responsibility (EPR) laws for paper and packaging in the United States. 

So far CAA has been selected by California, Colorado and Maryland to steward their programs. 

The following information is directly sourced from Circular Action Alliance if you would wish to better inform yourself on policy or the organization. 

States with PRO Requirements for Paper and Packaging

Oregon's SB 582 requires requires producers of residential and commercial packaging, printing and writing paper, and food service ware to join a Producer Responsibility Organization (PRO), and through the PRO, fund the end of life of those materials, which includes processing and recycling.  

CAA is preparing to be a PRO in Oregon. On September 1, 2023, CAA provided the Oregon Department of Environmental Quality (DEQ) with a letter of intent indicating that the organization will submit a program plan by March 31, 2024.

DEADLINE FOR PRODUCERS TO JOIN PRO: July 1, 2025

California’s SB 54 requires producers of residential and commercial single-use packaging and plastic single-use food service ware to join a Producer Responsibility Organization (PRO), and through the PRO, fund the end of life of those materials, which includes processing and recycling. Additionally, the PRO must remit to the state $500 million each year, starting in 2027 and ending in 2037 to be placed in the California Plastic Pollution Mitigation Fund. 

On January 8, 2024, CAA was selected by CalReycle as the state’s inaugural, single PRO.

DEADLINE FOR PRODUCERS TO JOIN PRO: January 1st, 2024

Colorado’s HB22-1355 requires producers of packaging, paper products and food service ware to join a Producer Responsibility Organization (PRO), and through the PRO, fund and manage the end of life of those materials, which includes collection, processing, and recycling or composting.

CAA was approved by the Colorado Department of Public Health & Environment (CDPHE) as the PRO that will administer Colorado’s EPR law for packaging, paper products, and food service ware on May 1, 2023.

DEADLINE FOR PRODUCERS TO JOIN PRO: July 1, 2025

Maine's LD 1541 requires producers of consumer packaging material to join a Stewardship Organization (SO)*, and through the SO, fund the end of life of that material, which includes reimbursements to participating municipalities for managing packaging material that is both readily recyclable and that which is not readily recyclable.

CAA intends to respond to the Maine’s RFP to serve as its SO.

*LD 1541 uses the term Stewardship Organization instead of Producer Responsibility Organization.

In Maine, the SO must respond to an RFP released by Maine DEP by the fall of 2025.

DEADLINE FOR PRODUCERS TO JOIN PRO: Fall of 2025

Maryland’s SB 0222 requires the Maryland Department of Environment (MDE) to conduct a needs assessment of the state’s recycling system. Additionally, the statute calls for the formation of an Advisory Council to advise on the development of an EPR for packaging legislative proposal, and the appointment of a single nonprofit Producer Responsibility Organization (PRO) to represent the interests of producers.  

On October 18, 2023, the Maryland Department of the Environment (MDE) selected CAA to represent producer interests and serve as the single nonprofit PRO on the State Producer Responsibility Advisory Council.

DEADLINE FOR PRODUCERS TO JOIN PRO: SB 0222 does not require producers to join the PRO at this time. Report Needs Assessment Results to the Governor. July 30, 2024.