Oregon’s Recycling Modernization Act continues to add infrastructure.
This week the Oregon DEQ announced approval of Circular Action Alliance’s (CAA’s) responsible end markets (REM) program plan amendment, the latest piece to fall into place.
The amendment establishes how end markets and downstream facilities can demonstrate compliance with the state’s paper and packaging EPR program, creating a verification framework that didn’t exist before.
CAA is the producer responsibility organization (PRO) overseeing program implementation in Oregon. More than two years of technical work between DEQ, CAA, the Oregon Recycling System Advisory Council, local governments, service providers and end market operators went into the program plan amendment.
“Reaching this milestone reflects months of engagement with many interested parties, including active participation by the Oregon Recycling System Advisory Council, and sustained collaboration between CAA and the state,” said Cheryl Grabham, product stewardship program manager at Oregon DEQ.
The framework leans on existing third-party certifications where they’re credible, letting qualifying facilities apply them toward REM verification rather than duplicating documentation.
Kim Holmes, executive director of CAA Oregon, called it “a practical path for end markets to demonstrate compliance.”
The news comes as Oregon’s EPR program continues to enforce upstream. The state’s EPR packaging law was signed into law by Gov. Kate Brown in August 2021 and took effect in July 2025.
In April, DEQ released its first quarterly producer status list, flagging 250 companies including Papa John’s, Yamaha Motor and Hobby Lobby for failing to register, report and/or pay required fees. Penalties can reach $25,000 per day. CAA is now moving toward implementation guidance and verification audits.
At the national level, the organization has opened a public comment period on a draft Responsible Markets Certification Standard designed to support consistent verification across existing and emerging EPR laws.
