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EPR by State / Oregon
OREGON EXTENDED PRODUCER RESPONSIBILITY

Oregon EPR in 2026: current requirements after the federal merits ruling.

Oregon’s Recycling Modernization Act remains in active implementation. On August 27, 2026, Judge Michael H. Simon rejected the constitutional challenge in NAW v. Feldon. Producers should not treat the former NAW-member injunction as a continuing reason to pause registration, reporting, fee, disclosure or recordkeeping work.

Primary sources: Oregon DEQ and federal findingsNot legal advice
Prepared by EPRScope Research DeskAgency, court and statutory sourcesMethodology & corrections

Current operating position: the RMA was upheld on the merits. The February injunction protected NAW and covered members while the merits case was pending; Judge Simon has now decided those claims. EPRScope did not identify a public stay suspending the decision as of August 29, 2026. Watch for an actual court order—not an appeal announcement or party statement—before treating exposure as changed.

2026 OPERATING BRIEF

Oregon packaging EPR compliance checklist

This is the control sequence a legal, compliance or sustainability team should document before treating the Oregon record as complete.

Immediate action

Confirm the exact producer entity’s CAA participation, reporting and fee status, then identify any disclosure, exemption or corrective action that remains open.

Entity question

Reconcile the name used in Oregon and PRO records with the actual brand owner, manufacturer, importer, first distributor and corporate-family structure.

Evidence to retain

Retain published status, CAA records, supply reports, fee records, exemption support, notices, source versions and closure evidence.

Do not assume: the court did not determine that a specific company is or is not a producer, confirm an exemption or validate an individual invoice. It upheld the statutory structure against the claims tried.

Questions to resolve before sign-off

  • Does the exact legal entity appear consistently in DEQ, CAA and internal records?
  • Which Oregon exemptions were tested, for what period and with what supporting evidence?
  • Were supply reports and fees completed under the same producer identity now being monitored?
  • Does the top-25 disclosure requirement apply, and who owns the supporting life-cycle record?
  • Has a later court order actually changed the entity’s exposure, or is an appeal only pending or contemplated?

Minimum decision record

A defensible review should name the candidate producer entity, describe the commercial roles tested, identify the controlling sources and review dates, record the covered-material and exemption questions considered, and separate confirmed facts from assumptions or items requiring counsel. The record should also identify an owner and next-review trigger so the conclusion is not treated as permanently correct after guidance, litigation or corporate structure changes.

Check a company name →Check the deadline calendar →Review exemptions →Handle a missed deadline →

What are Oregon’s packaging EPR requirements?

Oregon DEQ states that producers of covered packaging, paper products and food serviceware must register with and become members of an approved Producer Responsibility Organization, report covered-product supply information and pay applicable fees. Circular Action Alliance is Oregon’s approved PRO.

ProgramRecycling Modernization Act
Approved PROCircular Action Alliance
Legal statusActive · upheld August 27

What did the August 27 ruling change?

The court held that the RMA does not violate the dormant Commerce Clause or the Due Process Clause. It found no discriminatory purpose or effect against interstate commerce, rejected the argument that the law’s burdens were clearly excessive, found sufficient DEQ oversight of the PRO and concluded that the program provides adequate procedural safeguards.

The ruling did not create new registration or reporting duties; those came from the existing law. What changed is the litigation posture. Producers—especially NAW members that had relied on the February interim order—have materially less basis for delaying current Oregon work while waiting for the district court. NAW says it disagrees and is reviewing next steps, but that is a party position, not operative relief.

Practical effect: keep the Oregon workstream active. Track any appeal separately, and change the operating record only if a later court enters a stay or other order that actually alters enforcement or obligations.

Read the full ruling analysis →

What Oregon EPR deadlines matter in 2026?

Oregon DEQ anticipated May 31, 2026 as CAA’s reporting deadline for 2025 producer supply data. DEQ identifies December 31, 2026 as the first life-cycle impact disclosure date for top-25 producers that appeared on both the preliminary and final lists. Certain newly added top-25 producers receive additional time under DEQ guidance.

The private-recycling exemption claim window for the 2027 fee year ran from January 6 through March 31, 2026. CAA may administer additional operational dates. Keep the source type attached to each date instead of presenting every PRO date as a statutory deadline.

Who is the producer under Oregon EPR?

Oregon DEQ publishes a dedicated producer-obligation resource because covered-product status and producer identity are separate questions. For multi-entity companies, brands, subsidiaries, manufacturers, importers and distributors should remain distinct until the facts support a producer determination. The constitutional ruling did not resolve those company-specific facts.

What are Oregon EPR penalties?

Oregon DEQ states that failure to register or become a member of a Producer Responsibility Organization is a Class 1 violation that can result in penalties of up to $25,000 per day.

Source discipline matters: Oregon combines statutory duties with DEQ guidance and CAA operations. EPRScope preserves whether an item comes from a court order, DEQ, statute or rule, or the PRO instead of presenting every source as the same type of authority.

What to keep in an Oregon EPR compliance record

Exact legal entity evaluated as producer.
Covered-product and product-category analysis.
CAA membership and registration evidence.
Annual supply-data reporting records.
Fee records and supporting calculations retained from the responsible system.
Exemption support and claim records, if relevant.
Large-producer disclosure evidence where applicable.
Litigation event, legal effect and next-review trigger.
DEQ, court and PRO source dates.

Official Oregon EPR and ruling sources

Oregon DEQ — Producers of Covered ProductsOregon DEQ — RMA upheld as constitutionalNAW v. Feldon — federal findings and conclusions, court-linked copyOregon DEQ — Life Cycle EvaluationOregon DEQ — Producer Exemptions

Oregon merits ruling

Separate the court’s holdings, NAW’s position and the current producer effect.

Packaging EPR litigation tracker

Compare entered orders with pending motions in California and Colorado.

Keep source-backed status, deadlines, evidence, changes and open actions connected to the correct company name.

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