Oregon's producer status list

In April 2026 Oregon DEQ published the first quarterly list naming producers that had not complied with the Recycling Modernization Act. It named 250 companies.

Last reviewed 27 July 2026 · Packfile is not a law firm and this is not legal advice

Oregon is the furthest along of the seven US packaging EPR states. Its programme has been charging fees since July 2025, and in April 2026 it did something none of the others have done yet: it published a list, by name, of producers that had not complied. The first list carried around 250 companies, and DEQ said it would republish quarterly.

Why this matters more than the fee

For most mid-sized brands the Oregon fee itself is not large — the state is about 1.25% of the US population, so even a substantial national brand may see a four-figure annual bill. The list is a different kind of problem. It is public, it is searchable, it names you to your retail customers and your investors, and it establishes a documented history of non-compliance that sits underneath whatever DEQ decides to do next.

The penalty exposure

Failing to register with a producer responsibility organisation is a Class 1 violation under Oregon’s Recycling Modernization Act. Per DEQ’s own guidance, civil penalties run up to $25,000 per day, and the Oregon Department of Justice may prohibit the sale of a non-compliant producer’s products in the state.

That second remedy is the one to take seriously. A fine is a number; losing the ability to sell into a state is a revenue event.

If your company is on the list

  1. Register with Circular Action Alliance today. It is free, it takes minutes, and it is the specific failure the list records. Do not wait until your data is ready — registration and reporting are separate obligations, and being registered with incomplete data is a much better position than being unregistered.
  2. Check whether you are actually the producer. Some companies land on these lists for packaging where the obligation belongs to a retailer (private label) or an importer. If that is your situation, say so in writing rather than registering for an obligation you do not hold.
  3. Check the small producer exemption. Under $5M in global revenue, or under one metric tonne of covered material into Oregon, and you are exempt on either test alone.
  4. Then build the data. Your 2025 supply report is what sets your 2027 fee, so the accuracy of it has a price attached.
One thing not to do. Do not assume the list is wrong because you have never heard of the programme. Every state EPR law places the burden of identifying yourself on the producer. There is no notification step you were entitled to and did not receive.

What Oregon does next, and what the other states are likely to copy

DEQ has committed to republishing the status list every quarter, which means the next opportunity to be named — or to have been removed — is never more than three months away. Colorado’s fees went live in January 2026 and California’s begin in January 2027. Public naming is a cheap and effective enforcement tool, and Oregon has now demonstrated it works.

Not sure which states you are obligated in? The free exposure check runs all seven threshold tests against your revenue and category in about ninety seconds. No email required.

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More on this

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