Oregon’s Department of Environmental Quality (DEQ) has opened a public comment period on an updated responsible end market (REM) program following a plan amendment submitted by Circular Action Alliance (CAA).
CAA, the producer responsibility organization (PRO) overseeing implementation of the state’s extended producer responsibility (EPR) law, filed the revised amendment on Feb. 9. The update is designed to accelerate rollout of the Recycling Modernization Act and refine how end-market verification for recyclable materials is conducted.
“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,” said Jeff Fielkow, CAA’s CEO.
The amendment introduces a comprehensive set of audit standards scalable at the national level, subject to review by Oregon’s Environmental Quality Commission (EQC). CAA drafted the plan to meet REM requirements around transparency, compliance, environmental soundness and adequate material yields, while protecting proprietary business information and maintaining market stability.
A proposed verification pathway will remain active until a formal third-party standard is developed with an ANSI-accredited standards developer and reviewed by the EQC. CAA noted the framework carries more stringent requirements than comparable systems in the EU and Canada.
“Oregon led by putting responsible end markets into law, and this amendment moves that work forward in a way that meets the spirit of the law,” said Kim Holmes, CAA Oregon executive director.
With the documentation submitted, the DEQ and the Oregon Recycling System Advisory Council will review the plan and issue approval, conditional approval or return it to CAA for further revisions. If sent back, the organization may submit a third version.
Public comment closes March 27, 2026.
