EPR Initiatives Advance: Circular Action Alliance Provides Updates on Washington and Oregon

The Washington Department of Ecology (Ecology) recently named Circular Action Alliance (CAA) as the producer responsibility organization (PRO) to lead the implementation of the state’s extended producer responsibility (EPR) law.

As the designated PRO, CAA will work closely with the state agency, producers, and others to “expand recycling access for Washington residents and invest in a more effective and efficient system in the state,” CAA says.

CAA CEO Jeff Fielkow also says CAA will help build a program that “supports innovation, accountability, and responsible packaging stewardship.”

CAA will support producers in fulfilling requirements under Washington’s EPR law for residential paper and product packaging, including reporting, fee administration, and compliance with established recycling and reuse targets. 

“Drawing on our experience implementing EPR programs in multiple states, we are focused on delivering practical, consistent solutions that work for Washington’s recycling system,” Fielkow adds.

CAA is also the PRO in California, Colorado, Maryland, Minnesota, and Oregon.

Update in Oregon

CAA also recently submitted an updated responsible end market (REM) program plan amendment to the Oregon Department of Environmental Quality (DEQ). 

The amendment advances the implementation of Oregon’s Recycling Modernization Act (RMA) by strengthening the verification of recyclable materials as responsibly recycled, CAA says.

“The amendment strikes the right balance of achieving the regulatory and statutory requirements while also offering a practical starting point for engaging and educating the recycling industry on new requirements,” it explains.

End market verification can begin immediately within the system. Meanwhile, work continues on a formal REM certification standard. That standard could lead to broad adoption across packaging EPR programs, CAA adds.

“Oregon has been a national leader in defining responsible end markets, and this amendment strengthens that leadership with a practical approach we can implement right away,” Fielkow says. “By advancing a solution that is both rigorous and workable for end markets, we’re establishing a harmonized system that fully supports Oregon’s priorities while building a framework that producers, processors, and recyclers can rely on over the long term.”

The amendment is designed to meet the REM requirements of transparency, compliance, environmental soundness, and adequate yields, CAA says. 

“The amendment creates an interim verification pathway until a formal third-party standard is developed with an ANSI-accredited standards developer and considered by the [Environmental Quality Commission],” it explains.

The DEQ public comment period on the amendment ended Mar. 27. CAA will lead the first of two public consultation periods on the REM standard beginning in early May.

Lawsuit hearing scheduled for July

CAA also notes that the U.S. District Court in Oregon issued a narrow preliminary injunction in the National Association of Wholesaler‑Distributors (NAW) lawsuit challenging Oregon’s RMA. 

The case is proceeding, with a full hearing scheduled for July 2026.

“While CAA is not a party to this lawsuit, we are closely monitoring developments,” it says, adding that it has not changed how it engages with producers or other interest holders. “Our focus remains the same: continuing to implement Oregon’s RMA and other EPR programs that move us toward a more circular, effective recycling system.”