In every state that adopted extended producer responsibility (EPR) laws, producers—however they are defined by statute—must register with their producer responsibility organization (PRO) and submit data about the amount and types of covered materials they produce.
Registration gives Circular Action Alliance (CAA)—the official PRO in California and Colorado and the presumptive PRO in Oregon—an initial feel for impacted producers and types of materials in a market. Those are key components in the next step of assessing fees that producers pay for funding, maintaining, and improving the state’s recycling systems.
Accurate data from the initial reporting stage ensures that CAA fairly designates each producer’s fees based on its share of the materials they generate.
“Getting data and getting companies registered with the Circular Action Alliance is definitely something that will create that baseline that helps both the producers and the state understand what’s going to be accomplished,” says Andy Hackman, principal lobbyist, Serlin Haley LLP.
“Hypothetically, producers might determine that they need to fund an additional $5 billion in infrastructure investments if they really think they want to get to a 50% recycling rate. These types of things require that data to get to the overall objective.”
The fees can cover existing costs, as researched by CAA, and those evolving over time to support bigger-picture investments. CAA works closely with local governments, service providers, and material recovery facilities to understand the gaps and find opportunities for further investments.
Those collaborations give producers a say in the systems their dollars are backing and in the target rates they are being held accountable to achieve.
After registering, producers sign a producer agreement and gain access to CAA’s rich line of registrant-only content, guidance, and working groups. The monthly, 90-minute working groups began as general educational sessions but are becoming more prescriptive about reporting requirements and how to organize data as states finalize their regulations.
But what if a company remains unsure of its status?
“We’ve been encouraging companies that feel there’s ambiguity to register, in an abundance of caution,” says Olivia Barker, CAA spokesperson.
“The application process is free and deliberately simple. Any amendments needed as circumstances change are penalty-free. It is nonbinding in that sense.”
Many states remain in preliminary phases. Each sets its own timelines for registering, reporting data, and submitting fees. Key registration and reporting deadlines include:
- California: The preliminary deadline for data reporting is August 31, 2025. The program begins by January 1, 2027.
- Colorado: Producers were required to register by October 1, 2024. CAA’s draft program plan was due on or before February 1, 2025. CAA’s preliminary deadline for data reporting is August 2025. Producers remit dues when the program begins in early 2026.
- Maine: Its environmental department contracts with a stewardship organization (SO), which is similar to a PRO, in April 2026. Producers register with the SO and report data in May 2026. Producers remit start-up fees in September 2026.
- Minnesota: Producers register with the PRO by July 1, 2025. Producers cover at least 50% of program costs by February 1, 2029; 75% by February 1, 2030; and 90% by February 1, 2031.
- Oregon: Producers must register with CAA unless they qualify for exemptions or intend to submit individual plans. CAA’s data reporting deadline is March 31, 2025. Producers will have fee obligations when the program begins by July 1, 2025.
For state-specific details and future milestones, go to the “States” tab at circularaction.org.
M. Diane McCormick is a writer and editor based in Pennsylvania.